ML19345E550
| ML19345E550 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 01/14/1981 |
| From: | Davisson M BECHTEL GROUP, INC., CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| References | |
| ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8102050123 | |
| Download: ML19345E550 (149) | |
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NCCLZAR hwdTORT COM!CSSION
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c CONSUMERS PCWER COMPANY DCCKET NOS. 50-329 CM,
50-330 CM (Midland Plant, Units 1 & 2) 50-329 OL 50-330 CL
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January 14, 1981 1-W 73g7,gt
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Savoy, Illinois t
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1LDR%X LAE.Idi f.
400 71.T M a Ave., 5.7. W'*H T~, C - Cs 20004 Ta.'.arh-= : (2001 554-2345 l7 3 p r
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I UNITED STATES OF AMERICA 2I NUCLEAR REGULATORY COMMISSION 1
3
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In the Matter of:
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CONSUMERS POWER COMPANY Docket Nos. 50-329 OM & OL i' 50-330 GM & CL j
6 (Midland Plant, Units 1 & 2 R
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a Savoy, Illinois
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Wednesday, January 14, 1931 2
10 u
Deposition of M.
T.
DAVISSON, a witness herein, z=
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called for examination by Counsel for the Nuclear 3
12 i
Regulatory Commission in the above-entitled action, 4
13 j
pursuant to notice, the witness being duly-sworn by m
J 5
I4 PATSY ANN STROH, a Notary Public in and for the state of e
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15 Illinois,, at the offices of M.
T.
Davisson, 4 College t
g 16 Park Court, Ssvoy, Illinois, commencing at 9:00 a.m.,
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i 17 3
January 14, 1981, and the proceedings being taken down I'
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3 18 in stenotype by PATSY ANN STROH and transcribed under i
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19 her direction.
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ALDERSON REPORTING COMPANY,INC.
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I APPEARANCES:
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On behalf of the NRC:
3 WILLIAM D.
PATON, Esq.
U.
S.
Nuclear Regulatory Commission 4
Washington, D.
C.
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On behalf of the A=elicant:
n 1
n 0j JOANNE GAIAREK SLOOM, Esq.
2 E
Isham, Lincoln & Beale l
6 7
One First National Plaza 3
Chicago, Illinois 60603 l
5 8
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Also Present:
9 i':
MR. LYMAN HELLER, NRC-DE-HGZ3 i
10 MR. FRANK RINALDI, NRC-NRR-SE3 i
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MR. DINESH GU?TA, NRC-DE-HG"'
II MR. HARI N.
- SINGH, U.
S.
Army Corps of i
8 Engineers, Detroit, Michigan 12 z=
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25 iI ALDERSON REPORTING COMPANY. INC.
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_E _X _H _I _B _I _T _S l
2 NUMBER DESCRI? TION IDENTI?!ED 3
i Professional qualifications of M.
T.
Davisson dated July, 1990.
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Figure 62 of Interim Report 5 of H
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MCAR 24, crack mapping.
70 R
- 5 7
3 Letter dated 3/25/30 from S.
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5 Afifi to M.
T.
Davisson.
73 f
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4 Memo from M.
T.
Davisson to
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S.
S.
Afifi dated 3/29/30.
74 ll.
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Consultants request for answers, 3
i handwritten portion dated
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j 13 June 28, 1979.
81 t
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6 Technical Specification for fur-15 0
h nishing, installing, and testing closed l
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g 16 end pipe piles, with handwritten note s
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from P.
K.
Chen, dated 12/8/30.
96 IO 7
Letter from M.
T.
Davisson to S.
S.
19 2
Afifi dated 4/15/80.
119 20 8
Drawing by M.
T.
Davisson dated.
2I 1/14/81.
126
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ALDERSON REPORTING COMPANY. INC.
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P RO C EE D I N G S 2
Nhereupon, 3*
M.
T.
DAVISSON 4
a witness herein, called for examination by Counsel for e,
the Nuclear Regulatory Conmission, having been first 5
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j 6
duly sworn by the Notary Public, was examined and t
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7 testified as follows.
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EXAMINATION SY COUNSEL FOR NRC I
Y 9
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3Y MR. PATON:
i 10 '
G Dr. Davisson, would you state your full name
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11 and business address for the record, plea'se?
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3 I
I2 '
A M.
T. Davisson, 14 Lake Park Road, Champaign, ji 13 Illinois 61820.
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5 14 Okay, 14 Lake Park Road is your residence?
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f 15 A
Yes.
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16 4
What is your business address?
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17 A
2217 Civil Engineering Bu'ilding, University a=
3 I8 of Illinois, Urbana, Illinois 61801.
1 19 G
That's not the address of the building we are I
n 20 in now -- this is 4 College Park Court, is that correct, 21 sir?
i A
That is correct.
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Do yet-have - a copy of your professional:
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24 ) qualifications?
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25,
MS. BLOOM:
I do.
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1 ALDERSON REPORTING COMPANY, INC.
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THE WITNESS:
It might be on my desk.
2 MS. 3 LOOM:
Here you are.
3i MR. PATON:
Thanks.
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4 MS. 3LCCM:
Let the record show that he is 5
j2 giving a copy --
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6 MR. PAToN:
I am going to mark as Deposition l
i 7
Exhibit No.
1, M.
T.
Davisson, and today's date which is A
3 1/14/31,a copy of a document that I have just been handed
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which is entitled " July, 1930, M.
T.
Davisson, Consulting 9
g 10 Engineer," consisting of two nu=bered pages, with three l'
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11 pages of publientions attached.
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(The document referred to was i
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s 13 marked Davisson Deposition
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14 Exhibit No. 1 for identifi-I
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E 15 cation.)
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16 3Y MR. PATON:
(Resuming) z 1:7 4
Dr. Davissen, are you a registered structural u
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5 18 engineer?
19 '
A Yes, in the state of Illinois.
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20 4
Do you know Professor Ralph 3.
Peck?
21 1
Yes.
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22 i G
How long have you known him?
23j x
Twenty-seven years.
24f 4
When did you complete your PHD work?
25 i 1
1960.
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ALDERSON REPORTING COMPANY. INC.
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Did you write a dissertation?
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2 A
Yes.
3 G
Do you remember the title?
4 A
The precise title I do not remember.
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5 MS. BLOOM:
Off the record.
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6 (Discussion off the record)
I 6
7 MS. BLOOM:
Back on the record.
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8 SY MR. PATON:
(Resuming) c z.
G What was the subject of your dissertation?
9 g
10 A
Suckline of oiles.
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Do you recall who your advisor was for tha*
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12 thesis?
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A Dr. Ralph Peck.
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G Did Dr. Peck teach any courses that you too<
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15 in your graduate studies?
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Yes.
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Do vou recall what these courses were?
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Yes, earth dams, advanced soil mechanics, l
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that may have been all that I took from Dr. Peck.
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.t-Have you worked on projects other than Midland 20 i
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22 A
Yes.
1 23 j
Q.
Can you tell me what.those were?
Can you i
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24 I itemi:e those, and if there have been so many that it's i
d 25 difficult to itemi:e, just tell me some.
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Yes, it's been a fair number of projects, ana i
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- doubt if I could reme=ber them all, i
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Fine, tell =e the las: three er four that you 4
1 4 jhave worked on.
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A Certainly the pile supported runway extensions n
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at La Guardia Airport in New York City; several cre decks
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in Cleveland; earth dam in Costa Rica: Marina Towers n!
3 in Chicago; McCormack Place original in Chicago, and as l
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z, an explanation, that's distinguished fr:s McCormack ::
2 9
- y 10 tha: was buil: after the fire; nu=ercus instances of z
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y 12 te working directly with Dr. Peck.
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How many years have you been associated wich
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14 him in working on projects?
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First association was approximately 1956.
15
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okay, and your estimony is that there have i
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17 been se many that it would be difficult for vou presently f
3 18 cc recall all of them?
19 A
That's correct.
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4 Okay, when did you -- excuse me just a second.
21 When did you begin your empicyment at the 3
22 i University of Illinois?
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What was your first title?
25 1
Research Assistant.
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Okay, what was your nex-i 'e after Research l
2 Assistant?
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A I'= not sure that I recall.
It may have been 4
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was i.is t ruc to r.
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Do you recall approximately what year that vas?
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1959.
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Okay, when --
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Perhaps in part of 1960.
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All right, sir, when did you -- what was your z=
3 11 next?
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'd 12 A-Assistant Professor.
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5 13 4
When was that?
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14 A
1960.
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Associate Professor, 1963.
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All right.
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Professor, 1971.
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4 Is that y'ur present title -- Professer?
19 a
20 A
Yes, that is correct.
l 21 G
Are you now in the Department cf Civil 1
22 ] gneineering7 l, -
23l A
Yes.
what department did ycc 24!
Did you star:
25 ' start in'in 1957
---I'm going to strike that questica 1
ALDERSON REPORTING COMPANY. lNC.
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and ask you a different question.
2 When did you first begin work in the Department 3
of Civil Engineering?
4 A
1956.
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Have you worked in that department centinucusly 5
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that time?
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A Yes.
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Ckay, who is the chairman of the Department u
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ci Civil Engineering now?
10 2
A Currentiv John Liebman, L-i-e-b-m-a-n.
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II Do you know who preceeded him?
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A Chester Siess, S-i-e-s-s.
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When did -- is it Dr. Siess?
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A Yes.
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When did Dr. Siess terminate his employment l
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A 1973 a o. n. r o x i m a t e l'I.
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- G When did he start?
Approximately what year 19 i
did he start?
5 20 A
1973 approximately.
G Who preceeded Dr. Siess as chairman of the 21 1
22 ! Department of Civil Engineering?
I' 23 ;
A Nathan Newmark.
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Dr. Peck was at one time in the Departm nt 25 cf Civil Engineering, is that correct?
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ALDERSON REPORTING COMPANY. INC.
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A That is correct.
2 4
Do you know what year he departed?
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A (No response) 4 App cximately?
pardon me -- 1975 e
5 A
From the range of 1950 4
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6 to 1973.
I can't recall any closer.
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7 Okay.
Have you ever discussed your work on l
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8 the Midland project with Dr. Siess?
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No, not that I can recall.
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Do you now, let's say in the year 1931, do you l
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see Dr. Siess from time to time to talk to?
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13 Is it correct that you have been retained by l
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15 projec-o i,
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Yes.
x 17 4
Okay, when were you retained?
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Soring of 1979.
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Do you recall who first contacted you?
19 N
20 1
Dr. Afifi.
21 Can you tell.me what you were retained to do?
4 22}
A Look at the possibilities of support for the i,
23 l service water pump structure.
I 24 I q
Do you have a written agreement with them?
4 25 i A
Yes, it's-a general consulting contract.
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1 ALDERSCN REPORTING COMP ANY. INC.
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When did -- strike that question.
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Is there any indication in the agreement as 3
to when it terminates?
4 A
Yes, it's a yearly.
3 5
G It's a year to year contract?
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6 A
That's correct.
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Dr. Davisson, I want to get back to what you
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were retained to do, and you indicated possibilities a
2 9
consider possibilities of support for" the service water
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Yes.
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12 7
Did they give you any instructions on what you eere to consider when you consider these possibilities?
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13
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14 MS. BLOOM:
I just want to know who they is?
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15 MR. PATON:
3echtel.
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g 16 BY MR. PATON:
(Resuming) l I
17
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Did Bechtel give you any instructions that you j
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ko 18 were to follow -- NRC regulations or anything like that?
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What did they tell you other than to consider-possibilities 2, n
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20 A
Nothing.
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21 4
That's it?
4 22 i A
Yes.
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23l Had you prior to that time done any work r
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24j similar to what they were asking you to do on a nuclear l
25 f power plant?
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ALDERSON REPORTING COMPANY. INC.
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A No.
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Did they anywhere along the line give you any i
3I instructions or advice or whatever on NRC requirements?
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A No.
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Are vou aware of any NRC requirements with N
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respect to the service water structure?
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7 MS. 3 LOOM:
I am going to object.
Can you j
8 clarify what you mean by NRC requirements?
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9 MR. PATON:
Sure.
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I 10 BY MR. PATON:
(Resuming) 6 z=
3 11 For example, is it a Category I structure?
a 12 '
3 A
Yes.
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I 13 4
What does that mean?
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14 A
All sorts of things, desirable and undesirable, j
15 that this is a structure that is nuclear safety related.
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j That's the best general description I can put on it.
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Okay.
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This means that it must function for the j
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doomsday requirements that are placed upon it which i
19 n
l 20 art part of the design requirements for the plant site.
21 You said " doomsday"?
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Yes.
f 23f G
What do you mean by that?
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A The earthquake, tornado.
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25,
4 okay, you say -- I'm sorry, go ahead.
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1 ALDERSON REPORTING COMPANY. INC.
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A And effects that might come about because of the 2' earthquake or tornado are thrown in along with the 3
normal design requirements for the structure.
4 0
You say the earthquake are you talking I
g 5jabout any particular eqrthquake?
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6 A
With respect to Midland, it's a little difficult 7.
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to imagine, but one has been generated for it.
8 G
Why did you say with respect to Midland it's S
9 difficult to imagine?
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t" 10 A
It's not earthquake country.
E 5
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Oiay, are you aware of any current discussions a
12 '
i going on between the staff and Bechtel with respect 1
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and Consumers -- with respect to what's the appropriate 11
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n I4 earthquake to consider in this case?
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1 I have no direct knowledge et the discussions.
15 g
g 16 I have heard rumors i
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G Okay.
Now 5
I8 that you are aware of NRC requirements, at least to the N
2 extent that you have just testified to.
Where did you 19 a
f 20 ' acquire that knowledge, or how did you acquire that 1
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2I knowledge?
l 22,
A By osmosis.
Some of my colleagues have been l
I 23j involved with nuclear plants for a long time, and more i
i 2# l specifically and more directly with respect to Saitly.
f 25[
G Are you a consultant to the NRC on the Sailly; 4
1 ALDERSON REPORTING COMPANY. INC.
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I Icase?
2 A.
Yes.
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- want to stay with =y questions about instruc-1 4 ltions that you go~ from 3echtel.
Did they ever instruct i
5 lou, or did they ever advise you at any time concerning e
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g 6
NRC requirements?
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7 A
No.
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8 MS. 3 LOOM:
Can we go off the record?
J 2
9
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(Discussion off the record) 10,
MS. SLOOM:
When you say NRC requirements, in
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h II ; effect he is thinking did they tell you these are NRC 3
I 12. requirements, and I think you may be asking a broader
=
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j 13 question, and I am not sure were you given certain
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5 I'd specifications or certain details to follow without any M
15 headliners.
I think it's unclear.
.=
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10 3Y MR. PATON:
(Resuming) z 17 G
Okav, whether vou call them NRC recuirements u
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t or not, did ther give you any other instructions or
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E 18 r
"a 19 constraints or limitations on the design?
n l
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Specifically, no, but it'was kind of common j
2I ' knowledge that we were looking at the earthquake and the 11lccher things that go along with Category I structures, and 23}I don't think we have a specific discussion on this.
i 24 !
?
Okay, maybe the short answer to that is that 25 ' you are the expert and that's why they retained you?
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ALDERSON REPORTING COMPANY. INC.
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I A
Let's hope so.
2 4
Okay.
Has there been any change in the scope i
3 lof work that Bechtel requested you to do since they first 4
retained you?
s 5
1 Yes.
A
~
2 6
4 What was that change?
R 7
1 Mr. Gould, Charles Gould, who was primarily t
3 concerned with the underpinning from the auxiliary z.
structure has changed empicyment as of August or September 2
9 10 ' of 1930, and because of his new employer, he apparently l
=
cannot function further for Sechtel, and I have been asked II I
3 12 E
to share that responsibility with others that Bechtel's I
l 13 project management have engaged.
G Before you were retained in the spring of 1979 f
x 5
14 C
=
3 did you attend any me: sting with Bechtel or Consumers l
15 z
j 16 or the NRC concerning Midland?
l
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No.
l l
M w
I y:
18 MS. BLOOM:
Can we go off the record for a
- 8 I9 E
second?
n 20 (Discussion off the record)
[
i 2I MS. BLOOM:
Back on the reccrd.
l i
22 l 3Y MR. PATON:
(Resuming) i I
i G
What was your involvement in the Midland soil 23 og i settlement problem before December 1979?
2 25 i MS. BLOOM:
There has been no showing that he r
I i
i ALCERSON REPORTING COMPANY. INC.
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1 4
1 I i had involve =ent with the scil settlement.
He testified 1
2j he was invcived with doing support.
J 3
MR. PATCN:
Ckay, I an ecuating the two, and l
4 j! think all the witnesses have, but it's all right.
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5i 3Y MR. PATON:
(Resuminc) n n
a 6"
3 Ycu indicated you were retained in the spring N
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7 of 1979 with respect to the service water s ucture a:
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3-A42 a d3 n
9 z.
A That is correct.
I g
10 Tell us what vcur activities were for the z=
3 II re=aining part of 1979.
5 12 g
1 A:: ended a meeting at Midland in the spring 13 i
g of 1979, viewed the structure, and in fact : viewed all
=
14 c.,
.w... e s..
......s.
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j 15 i The meetin~ concerned all of the areas tha:
v
=
j 16 were under investiga:ica at the time, and se it was not
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specifically service water pump structure, and locked e_
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18 at the aux building also, and I did that in conjuncticn --
19 i
MS. 3LCOM:
Off the record.
a 1
20 '
(Discussien off the record) 2I i
THE *d!TNESS:
The attendees at the =eeting I 1
22 j recall being Mr. Gould, Dr. Afifi.
They were cuite 1
i 23 vague abcut how many other meetings might have taken place, but de knew there were =ee:ings where the[
24
'5 described specifically :ypes of fixes that sight be ALCERSON REPORTING COMPANY. INC.
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I considered for the service water pump structure.
2 3Y MR. PATON:
(Resuming) t 31
?
Okay.
New, my cuestion was :c tell me ycur 4
activities for :he remaining part cf 1979.
Have you 5
g finished ycur answer?
a 2
6 A
To the best of my recollection.
?
l' 7
C All right, let me ask you this:
How much n!
3 total time did you spend with respect ec your censulting a
9 Sechtel on this service water structure in the year 1979?
z:
10 z
ten davs.
A Perha s
'e
=
3 II a
Ten full days?
3 12 '
E A
Yes.
=
13 5
o k a v., v.ou indicated v.eu attended a meeting.
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let's say a day?
.i 14 Did that take
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.N A
Yes.
7
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16 i
4 O k av..
What did v.eu do the other nine dav.s?
1 A
several other meetings;1 a
- 7 H
A I as sure that I attended t
3 I8 3
With 3echtel do you think?
i "a
19 A
With Bechtel, and information was being senerated n
20 at that time on soil conditions, because a boring 2I program was going on, and some labora: cry testing !
j 22 ! believe was taking place, and a definition of the infor-l 23 marion was in-process, and that information was being
,4i sent on to me and I reviewed it as it came in.
25 q
At any time during the year 1979 did ycu
- i. '
1 ALDERSON REPCRTING COMPANY. INC.
i L
17 1
think that you had enough information to begin determining 2
which alternative would be selected?
4 3{
A I think several could have been used.
4 4
Did you ultimately -- you ultimately arrived g
5 at the conclusion that you would use piles and you would 9
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~
2 6
use a corbel -- that's the alternative I am referring to.
R 7
When did you -- did there come a time when i
i
-n 8
you finally decided that would be the alternative you i
d_
9 would use?
z, 10 A
I did not decide which alternative.
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I have to make an assumption that it was the
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You are referring to 3echtel?
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That's affirmative.
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scheme.
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You made a suggestion and ultimately you 20 '
21 learned that they arrived at the same conclusion where
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Apparently.
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When did you make your suggestion?
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ALDERSON REPORTING COMPANY. INC.
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A (No response) 2 4
Months is close enough.
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A 5pring of 1979.
I am sure tha: the ideas and 4
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someti=e during 1979.
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You just testified, though, the spring 9
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'79, and I note that's when you were retained.
So, 10 II 4
it seems like it was fairly soon.
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A Right.
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c Within a month or so -- it seems like it was 13
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fairly soon?
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A Right.
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Within a month or two after you were retained?
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A I would think so, yes, t
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4 okay, that was 1979.
In the year 1980 how much l I8 i
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time did you spend on this project?
20 A
Again, approximately ten days.
j 21 And the year 1981 how =uch time have you G
22 1 spent en the project?
t 23 1
1 Yesterday and today.
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okay.
Ecw many site visits did you maka to 5
Midia.4d.in each of those three years, starting in 1979?
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i 19 i
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A At least one in 1979, at least one in 1930, i
2 and -- probably two in 1990.
I think I was involved with 1
3 la hearing.
1 4
7 okay, I heard you say one in 1990, and then s
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A Probably at least two in 1930.
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A Nothing.
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10 We have described a scheme, if you will a70ept l
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Yes.
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Was that your number one choice?
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No, that was probably my second suggestion.
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What was your first choice?
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Check the building out and see if you have to j
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18 l
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the buildings so that it could function as a cantilever.
19 M
+
i 20 '
Did you -- who eliminated that possibility?
l 21 Was that you or was that Sechtel?
3 J
22 i A
That would have to be 3echtel's project team.
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3 Can you state just as a general statement 4
24j I would assume that the remedy that you have described 25 as your number one choice would probably be less costly I
ALDERSON REPORTING COMPANY. INC.
1 20 1
t I
in dollars than the remedy they are pursuing?
2 A
Certainly.
i 3li Do you receive copies of the responses to 4
50.54 (f) questions asked by t 2 NRC7 It's well known, 5
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,a: least to these fellows.
Are you familiar with that n
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expression?
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A Perhaps.
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Do you receive from Bechtel in your professional J
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judgemen al? the information that you believe you need 10 j
to perform the work they have asked ycu to perform?
II A
Yes.
3 12 5
4 Have you ever asked them for additional r
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information that they have not sent to you?
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A No.
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C The retainer agreement that you have with I
i do you know what it says with respect to what f
j 16 3echtel a
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v.ou ere supposed to do?
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No, it's quite a general. agreement that does
- 6 19 i
not pertain specifically to Midland.
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Okay.
l-21 A
I am a consultant to Bechtel on several proj ects.;
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G For how many years have you been a consultant i
23 ^ :o 3echtel?
1 24
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Probably three years.
1 25 '
4 Is_there a written description anywhere that i
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f I !you are aware of,cf what it is v.cu are supc.osed to de 4
2 with resc.ect c this case -- the service water structure?
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- do not recall one.
I 48 G
- don't want to ask you about dellars, but :
i 5i jus: vant to pose ene question, and tha: is are you e
4 2
6
- c. aid bv. the dav. or bv. the.icb cr --
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G Per day, Okay.
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Dces 3echtel retain Oc your knowledge any z.
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- 's my understanding sna: project is respcn-E 13 sible for retaining a fir = cf Mueser-Rutledge-Johnsten I.
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T h e v., a r e addressine the remedy at the service i
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20 1
Yes.
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Do you ow where that firm is located?
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New Ycrk C' y.
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1 ALCERSON REPCRTING COMP ANY. INC.
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From those conversations you are not able to 2:} discern that their responsibilities are any different
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3 lthan yours?
4 A
I have not had that kind of conversation with e
5 them.
I shook hands with them, passed the time of day.
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4 The two occasions that I have met ceople from that firm
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5 these details.
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5 indicated any disagreement with the remedy that has been 3
11 selected by Bechtel?
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I am unaware of it.
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4 Okay, has anyone to ycur knowledge at Consumers a
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or Bechtel expressed any disagreement with any aspect
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of the remedy that has been selected by Bechtel at the
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service water structure' s
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A I am unaware of it.
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Have you submitted any written report or any 19 -
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1 20 service water structure?
21 '
A No formal report on the recommendations.
I 1
22 ) function generally as a consultant to the geotechnical 23 1 group, which are in turn -- function as consultants i
24 ii to the project at the project's discretion.
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!s your main contact there Dr. Afifi?
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ALDERSON REPCRTING COMPANY, INC.
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1 A
Affirmative.
G You have been retained for about a year --
3 almost two years -- and at no time during that time have 4
you given Dr. Afifi any written report or results of a
5 v.our consultanev.?
3
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No, there has been review of things.
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7 we are dealing with advice which the geotech group n
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n incoro. crates and e.robablv. passes on in memos ad minutes w
9 g
of meetings to the project.
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4 Okay.
I 11 j
A I have not been asked to do a design report i
12 '
5 as such.
That would ordinarily be done by the geotechnical i
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G Would you say that the situation I have 9
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described where you have been retained for a year, or l
I6 where you haven't given them a i
j almost two years, d
17 2
written report, is that unusual?
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G You said a minute ago something like you j
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20 i
were not retained to do design work -- that's not 21 l
exactly what you said, but you said something like that.
22 l
j My question is what exactly are you retained l
23,t to do -- advise Dr. Afifi as the project goes along l
or what?
You were not retained to design, is that" 25 i' correct?
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4 l
ALDERSON REPORTING COMPANY, INC.
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24 1
A (No response) 2 S
To design a remedy?
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8 3j A
That is correct, I do not do the detail of a
4 tthe remedy in its totality.
since you don't do the c
5 7
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detail design, what do you do?
R 7
A In this instance I recommended several possible f
8 approaches to the problem.
The project, I presume, has 2
z.
gone through these approaches and determined their 9
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10 feasibility or lack thereof, and have arrived at which z
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I4 or one or more people, go to work on it for a while; 4
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15 then there is further interaction, and that process has a
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16 gone on for some time, and it appears like the driven j
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I7 pile underpinning approach and the services that I am a
3 5
18 cerforming with resc.ect to that ac.c. roach with regard to rs 19 s
the selection of the pile driving equipment, and the n
20 '
testing, and the locking-off procedures,-and other items f
21 of construction techniques, but not the structural 22 1 details of how that pile is connected into the structure i
?
Does somebody else have that responsibility --
23 24 ] the structural?
l 25
.t That's 3echtel project.
j ALDERSON REPORTING COMPANY. INC.
3 3 I
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G Might you advise them in that regard after they, for example, make a design or make a proposal in l
2 3 '.that regard?
I A
Caly insofar as it would interact with 4
g jacking in the load from the piles and locking it off 5
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from the piles.
These piles are going to be driven, t
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aren't they?
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jacking.
I thought jacking and driving were two different t
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things.
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to the structure, so that when all construction is I
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withdrawn, the piles will be carrying the load.
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q How frequently
-he year 1990 did you
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A Probably around once or - twice per month.
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Would you say the same thing for the year 19797 21 A
Yes.
I 22 l Did you meet with him, or was this mostly.
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24 4
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Both.
I 25 4
Do you know why 3echtel did not agree with i
ALCERSON REPORTING COMPANY. INC.
26 I
your first suggestion of bracing the structure?
A I can't recall that I have a direct communication.
2 I have the presumption that checking it out they found 3
4 scoe :4 tre s s e s excessive.
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You don't recall any conversations ycu had 5
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with anybody about that?
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There may have been, but I do not recall them.
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I think thev. were probablv. concurrent.
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Okay.
When you were retained did you go to 3
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Ann Arbor?
13 A
No, Midland.
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4 You met Sechtel at Midland?
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A Affirmative.
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16 Did you talk to Dr. Afifi that day?
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A Yes.
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4 Was that -- were you up there one day or two I
19 i
days?
How long were you up there at that time?
n 1
I don't remember, it might have been two days.
0' 21 Have you got any way to determine excuse 22 1 co ahead.
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A I believe Afifi was at that meeting.
He may t
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- or may not have been.
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Do you have any way of determining hcw soon t
t, ALDERSON REPORTING COMPANY. INC.
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I lafter that visit you made your first recommendation to 2
3echtel?
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A Not easily.
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For example, was this first recommendation s
5 in wri inc7
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I don't believe it was, no.
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Do you recall whether you met with Dr. Afifi,
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or did you just call him up on the phone?
a 9
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to a firm recommendation.
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Would you agree with the statement that
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M two days?
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No, I thought the problem was relatively simple 19 at least the part that I was looking at.
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Did you know at that time the nature of the l
20 l
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- 117 i
J 22 l A
Yes, the underlying till was fairly well i
1 23 l investigated fcr the plant site in general.
E 24 i 4
And you had that information during that one 25 or two day first visit?-
k, ALCERSON REDCRTING COMPANY. INC.
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A Yes.
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A Yes.
4 4
That would have been one of your important i
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considerations, I assume, wouldn't
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A ch, yes.
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C When you visited the building -- you did visit 8
the building on that occasion?
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9 A
Definitely.
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3 h
II A
I do not recall observing cracks.
3 12 '
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Do you recall observing cracks since that ti=e?
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A No, I would say it would be highly unusual i
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@sj 15 see any cracks, but I did not see any cracks that told i
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that time.
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All right, I thought you indicated a minute
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3 ago that you didn't see any cracks.
20 g
n,g.s try again.
I 21 G
It's either you didn't see any, or you didn't 22 see any that worried you?
23 A
Let's take the latter.
I didn't see any i
24j cracks that I associated with a potential lack of
~
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- S' support from the fill.
l i
- ALDERSON REPORTING COMPANY. INC.
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29 r
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okay.
Considering your expertise, do you have l
1 4 2 l the ability t-walk into a building of that kind and look t
3 ! st cracks and determine whether they have safety sig-4 nificance?
n 5
A To an extent, yes.
M j
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And that would be determined, at least in R
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part, on the width of the crack, I assume?
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A Width and location.
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And direction, or --
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Yes, orientation.
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I don't mean to press you, but I do want to 3
y 12 make sure.
Is it correct that your testimony is that
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you, in fact, did see some cracks and reached the con-l 13 i
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14 clusion that they were not of immediate concern to you?
j 15 A
Let me try to explain this.
Most any concrete t_
j 16 structure will have some cracks in it.
If one wants a
1 to look, one can find them.
I am sure that if I were j
U 17 5
18 to seek them out, I could find some, but I do not recall l
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19 seeing any that I associated with a problem.
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20 4
Okay.
You still haven't answered my question.
l 21 Did you see any cracks?
l 22 :
A I don't recall.
I, 23 ;
2 okay, that's fine.
24j Are you aware of any correspondence or dis-I i
25 cussion that has taken place between the staff and i
l n
ALDERSCN REPORTING COMPANY. INC.
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4 30 f
f I
Sechtel in the year 1980 about cracks at the service water 2
structure?
a 3j 1
I have no direct contact on that.
4 l 4
Regardless of direct contact, have you seen 5
g any papers that indicate to you that there has been any n
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exchange between the staff and Sechtel with respect to R
I
^
7 the cracks at the service water structure?
i 8
A A
I think I had heard someplace that somebody 2
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from NRC was waving a red flag that there were all kinds 9
j of cracks down there, and I was curious about this because 10 II I certain1v didn't see them when I was there.
a 32,
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When you say waving a red flag, I get the 6
inference that you don't agree that there is a concern l'
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1 14 2
in that area, is that correc*'
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Not from any observations I have made.
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Okay.
Now, I want to know what observations j
j 16 1
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k Y
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Yes, I crawled all through that structure.
l
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20 Tell me about any knowledge that you have of g
cracks in that structure since the spring of 1979, and II i2!ifyouransweristhat it's simply the same as it was i
23 '
' in 1979 t
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A I have not made any detailed inspection of it
'4 i since that time.
l 25
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ALDERSON REPORTING COMPANY. INC.
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How many times in the year 1930 did you go 2, into the service water structure or did you observe the i
3 I service water structure?
4 A
At least once en the inside, but a very s
5 limited portion of the building.
N
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Q.
Did you see any cracks at that time?
R
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No, I wasn't looking for any either at that n
8 time.
Q.
Okay.
Do you know whether Sechtel has per-9 2
5 10 formed any kind of analysis concerning the cracks at the l
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11 service water structure?
j 3
'2 12 A
I am unaware of there being any cracks to i
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- such,
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that would be done by Bechtel's project, and I am not l
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involved with it.
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If I say to you the NRC asked Consumers 16 N
17 50.54 (f) questions, does that have any meaning for you?
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I know there is a language of that type.
19 g
G All right, let me ask you this:
Do-you t
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l 20 know whether or not there are seven or eight volumes of.
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21 information prepared -- or more -- prepared by Bechtel 22 i and Consumers and sent to the NRC under a title " Responses l
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1 i to 50.54 (f) questions"?
4
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Do you know if such papers exist?
A That conceivably =ay be seven or eight volumes i
25 i l
ALCERSCN REPORTING COMPANY. INC.
i 32 i
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of which we have a copy sitting here in the building and 2i Professor Hendron has that.
3 3
Have you --
4 A
If I need it, I can go get it.
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Have you ever read those volumes?
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It seems that I have got into them for certain l
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areas at times.
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G To whatever extent you have looked at those
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volumes, you don't recall having seen anything with any 9
i
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11 A
I don't recall.
4 i
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In your visit in the spring of 1979 did you h
13 '
any water leaking through the west wall of the l
see
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I don't recall.
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G Did you attend a meeting at Midland in February, j:
16 w
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q 17 1990, where 3echtel and Consumers were in attendance i
E 18 ; and the NRC also was in attendance?
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1 I did attend a meeting:
the date I do not e
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20 recall.
There was one in 1980 where. Consumers, Sechtel, l
l l
21 and the NRC, the Corps of Engineers, the Navy, and 1
22 l probably Intervenors were there.
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G Was there any discussion of the history of 24 the cracks at the service water structure there?
1 25 :
1 I don't recall.
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ALDERSON REPORTING COMPANY. INC.
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1 S
Is it difficult to do analysis of cracks of 2
reinforced concrete structure?
a i
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A That would depend upon the nature of the problem.
4 Cracks may be associated with shrinkage, or they might s
5 be associated with stress.
A j
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I am excluding shrinkage cracks.
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7 MS. 3 LOOM:
What kind of analysis are you l
A 0
asking about?
-J 9
MR. PATON:
Well, I'll just ask him, and if he 4
10 doesn't understand, that's fine.
2 E_
l II THE WITNESS:
I'm afraid the question is far 1
S 4
f 12 too general.
=_
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(Resuming)
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4 Eliminating from my question shrinkage j
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IS cracks, is it difficult to do an analysis of stress j
16 cracks in a concrete reinforced structure?
j z
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No.
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Were you retained to consult with respect to i
3 the diesel generator building?
l 19 1
20j 1
No.
f 4
21 1 4
Were you retained to consult with any structure
)
i 22 l other than the service water structure and the electrical i
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i penetration areas?
24l g
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25,
g Okay.
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ALCERSON REPORTING COMPANY. INC.
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Sy electrical penetration, you mean the aux 2
building?
3' G
The auxiliary building -- you would incl"de 4
in that the fead water isolation valve pits?
5 j
A Yes.
nj 6
Okay.
So, we have those three -- the service R
7 water structure, the electrical penetration areas, and i
3 A
the feed water isolation valve pits -- the last two of C
9 z-which are the aux building.
10 j
Were you retained to consult with any other II structure?
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4 12 <
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No.
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G So, you were not retained to consult with l
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respect to the borrated water stora e tanks -- that's 1
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a correct statement?
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That is correct.
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1:7 3
were you retained to consult with reseect to f'
any underground piping or conduits?
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19 i
A No.
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4 Were you retained with respect to the dike?
21 A
No.
O Dr. Davisson, I want to give a preamble to 1
23
=y next question, and it arises from my own unfamiliarity i
24 I with the work than you do.
~
5l The thrust of my question is to find out, for i
t ALCERSON REPORTING COMPANY, INC.
s' 35 i
where you I
example, would the service water structure 2,and Bechtel are with respect to the design and the I,
3f resolution of the problem.
4 Now, I just want to read you some words that I 4
e 5 ! understand are involved when you have a problem like n
j 6.this and you go about fixing it you might look at I
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alternatives.
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I will read you this list, and I know you are 9
going to be familiar with these words, my questita when 8
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5 10 ' I get all done is to ask you to then give me your z_
j II version of this -- whefe you start, what the next step 3
i is, and then I want to ask you where are you in the 12 l!
process that I'm going to ask you to describe.
l 13 a
5 I4 The processes that have been described to me
---j 15 involves you outline alternatives, you make a quick
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N I7 then you may refine the model for the selected alternative, !
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18 you analyte to determine available safety =argins, you l
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compare the safety margins with allowables, and you 39 I
i 20 conclude then with respect to the safety of the structure, 21 and then you in some order that is not always the same, 221 you do drawings, you do specifications, you do final 23fdesigns, and then you put out for a bid.
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.t Yes.
25 '
S Would you tell me step by step with respect ALCERSON REPORTING CC.MPANY. INC.
26 I
I I ?c the service water structure what has been done e
what has been ec=pleted with respect Oc the ite=s tha 4
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,3 assu=e what thev have done.
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20 that you would have te obtain from the responsible 21 l1 parties or the structurai or project group, and when :
22 4' s a v. o.rciece, it can mean varicus aspects cf the desips,
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ALCERSCN RE?CRTING CCMPANY. INC.
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37 I
jasking me.
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- dhen I =ade preliminary recommendations on the 3! fixes that could be considered, the reasonable thing is 4
for project to have gone through the preliminary review a
5 4
of what would be involved in these various fixes and to n
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1, Line them up on an order of desirability from an en-R 7
gineering standpoint, and that necessarily includes costs.
3 If you have four fixes, and they are all four 9
i satisfactorv, then most normal people would take the d
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I am not in a position at all to be sure 6
1:7 exactly what structural has done.
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18 come secondhand through the geotechnical group at Bechtel.
E 19 A
S I do want you to tell =e that secondhand.
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20 am not asking what you are absolutely sure of.
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22 i{ meetings that have been held on the subject, but outsida 23 , of that, it generally goes from projec: to gectechnical
'4 i I back to me.
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- Okay, i
ALCERSON REPORT'NG COMP ANY. INC.
38
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MS. BLOOM:
With that'I have a problem with 2
your question.
First of all, I don't remember it and I i
3 don't know if he does.
4 Secondly, it assumes an order in things that not necessarily true.
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MR. PATON:
No, I read to him a lot of words a
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I think he understands.
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91 MS. 3 LOOM:
So, you are not assuming any order?
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10 MR. PATON:
No, not at all.
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I think you need to also under-a 17 stand that project is responsible for the design that a
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M 20 SY MR. PATON:
(Resuming) 21 g
I think you indicated a while ago that the 22 l Mueser-Rutledge firm was a consultant to project and you 23 :, are a consultant to Afifi?
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.t Yes, that's my understanding of it.
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3 Okay, I understand that, too.
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ALCERSON REPORTING COMPANY. INC.
4 39 I
Is that the end of your answer?
You have 2 explained to me things I have to understand, but I 3
don't think you responded to my question.
4 A
The question that you are asking is where are l
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Start at the beginning and tell me which a
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ones you have done.
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~ dgeidad that adding bracing to the building i
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second suggestion, and found that it was workable a
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2 it is now supported on piles on the cantilever portion 19 M
6 20 instead of having soil support spread underneath, and in l
21 the process of so doing, they would find what loads i
1 22 i finally have to be resisted by the piles.
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- 4lthat this has been done and we now have a better ds-25 ' finition of the loads that will be on the piles.
ALOERSON REPORTING COMPANY. INC.
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4 Approximately when was that meeting?
I 5 2
A December -- the middle of December, 1930, 3
With regard to this process, I am concerned 4 l about the mini =um si:e -- the wall thickness of the pipe s_
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they can be jacked and locked off inte the structure.
E The structural analv. sis of the m. ile c a e., or 9
's corbel as you have been calling it, rests serie:17 with
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-he wall thickness.
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The size of the pila l
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G Can you tell me just generally what tha:
2 concern is?
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you talking about people who do not work for Afifi?
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Absolutely, they do not.
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It's a different group?
A Absolutely.
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Okay, I think I know what you mean.
22 Do you have direct involvement with the size 23 I of the pile?
I think you did indicate you will consult 24 el
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Yes, buu that would be a responsibility'--
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I guess Dr. Afifi wculd dc that i
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ccordination as opposed ec you?
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ALCERSON RE=CRTING CCMPANY.'INC.
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are ones on which you expect to do some consulting work 2
to Dr. Afifi, is that accurate?
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Yes.
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Can you tell me just generally what are the 5
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We need to have a procedure that is consistent R
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What is your concern with respect to load z=
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Okay.
Do you now think you -- I think you n
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A Yes.
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So, now I gather that the load' capacity.
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21 concern is to make sure that you get a pile that can 22 ! accomolish that job?
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A That is correct.
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That concern there obviously will effect the 25 design of the pile?
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Yes.
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When you sav. that concern,
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Testing -- can you tell me hcw the process
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generally works and hcw you wculd test the piles?
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Have vou determined that vou are c.oin: to 1
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drive these piles -- I'm not sure I get this correct 19 twentv. feet into the till, is that correct?
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A No, that does not sound ric.ht.
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Have v.na I
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determined that you will drive these' piles -- have you l
i' ALCERSCN RE.=CRTING COMP ANY. INC.
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2 ',
A They will be drive to the till and then to 1
3 'a practical or refusal criterion fer the hammer 4
cushion O.ile system that is selected.
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A Probably be twenty blows per inch final
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Has there been a calculation made that tells 3
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vou that if you drive
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4 Did you write that out?
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re.s in a graph form.
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Is. that among the papers that you showed us j
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I don't recall seeing it.
It might be in a 19 different file; I had another fellow de that for me.
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2I MR. PATON:
Off the record.
t 22 I (Discussion off the record)
'23 li MR. PATON:
Back on the record.
I 24 3Y MR. PATON:
(Resuming) i 25 '
S Dr. Davisson, is it fair to say that to the i
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ALDERSON REPORTING COMPANY. INC.
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l I 'best of your knowledge Bechtel is in the process of 2
refining the final design of the piles?
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1 What is the approximate distance between the I
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water structure?
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7 MS. 3 LOOM:
Excuse me, would you repeat that n
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9 (Question read)
Y 10 THE WITNESS:
Couple of inches.
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(Resuming) 3 y
12 4
Is there a possibility that the driving of the
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No.
2
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Does it come within your area of responsibility
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I7 the wall from the driving of the piles?
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Yes.
We have developed a procedure that would
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avoid damage to the wall.
M 20 0
What is that procedure?
?
21 A
Predrill each pile location.
22 }
q Dr. Davisson, I asked you a question'before, 23 and we have agreed I will ask again and you put your 24 l answer on the record again.
r 25 The question was describe generally'the 1,
ALDERSON REPCRTING COMPANY. INC.
1 47 4
5 i
I method that you are going to follow to test the piles.
2 1
The pile will be driven, concreted, probably I
3 'a deadload frame built above the pile and loaded, a 4
hydraulic jack will be inserted between the pile and the g
5 frame, loads will be applied to the pile by the hydraulic n
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time and loading.
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Will that test be conducted in the place
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where the piles will be installed?
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No, it will be in an adjacent representative z=
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Okay.
Just approximately -- within fifty. feet
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or a hundred feet?
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Within fifty feet.
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The borings already show that we have a e
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18 representative situation.
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You have a location?
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Yes -- no, we have not picked the final lo-j 21 cation.
It will depend a little bit on the logistics.
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Okay.
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The logistics has to be an :nput to the i
y' i selection of that location.
However, the nature o f the 25 l
support for the piles are primarily ott of the lower part l
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i ALCERSON REPORTING COMPANY. INC.
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48 4
i 4
I of the soil profile,which is fairly well documented.
2 You mean by that the till?
3.;
A Yes.
4 G
Will the jack impose the live load?
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A It will impose a load that will incorporate n"
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Okay, and the seismic load also?
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A Yes.
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Yes.
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G Would you describe that?
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The pile will be installed as prototype pile, t
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That pile will be pulled to determine the
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19 3
4 When the pile is pulled up, will it-stretch n
i 20 longitudinally?
21 A
Negligib ly, yes.
22l G
Okay, whatever that is,in your professional i
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- 4 negative skin friction?-
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A That is correct, it does not.
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When it stretches longititudinally, does it 21lcontract laterally?
3 1
In a negligible amount, yes.
4 G
Dr. Davisson, I want to clarify something that 5
c we have just been discussing.
You indicated, I think, that n
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you have not determined the exact location that you are
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going to make the pile test?
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I have not; it's conceivable that Bechtel u
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may nave.
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Okay.
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They may have alreadv. picked some locations 3
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that are possible locations.
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that will be encountered?
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look at the possible locations, and then among that z
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c.ick the one that will be ree.resentative.
18
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one pile?-
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That's the plan at the moment.
21 G
Is the till in the various locations where'the 22 ciles will be driven -- is that all the same, or is 23 'i the re any difference in the till?
24 i 1
There are possible variations.
lt 25 G
Sy possible, does that mean that you know ALDERSCN REPORTING COMPANY. INC.
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I or you are going to investigate, or what?
1 24 1
Our procedures take that into account.
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Well, what I want to know is what do ycu knew 4
about it now?
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Only what you see from the borings, but our 2
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Okay, so you are -- you are talking in circles.
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I am asking you wha z_.
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What dc you knew?
What dc the bcrings show?
5 10 A
The borings shewed a hard till material.
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For all --
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With respect to what I am dcing, I am not :cc
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Generally, what are these variations?
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A First of all, the centrol that-has been
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that if we are attacking the till with the same amount I9
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n 20 of force every time, and if the' fill does not choose to 21 resist the force, the pile will =erely continue to i
22l cenetrate until it does.
So, the pile tips will seek 23 [ their own elevation, and therefere take into acccune 24 l some of the variatiO*.s in the till.
D-In addition, the jacking system that is i
9 4
ALDERSCN REPORTING CCMPANY. INC.
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4 I
going to be used to jack the load into the piles before 2
attaching to the structure, provides us with an opportunity I
3i to check the load-carrying characteristics of each 4
individual pile before it'is finally fastened into the e
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It's very possible then that each of these b
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1 Yes.
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In the first twenty feet of the till that you 10 will encounter, is the till strength the same at all tz=!
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I am sure it's not.
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Who was responsible for designing the under-
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pinning to the service water pump structure?
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I don't know if you have established
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N I7 MR.-PATON:
If he doesn't know, he can tell u
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THE WITNESS:
I am at a loss for that question.
M 20 I thought that's just what we were talking about.
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MR. PATON:
We were.
Can you answer the t.
22 } question?
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'3I THE WITNESS:
Wait a minute.
I am not 24 i 3Y MR._PATON:
(Resuming) t 25
?
You indicated that a lot of people had varicus ALCERSON REPORTING COMPANY. INC.
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1 responsibilities with respect to the service water structure.
I 2
A Yes.
3 G
Is it the structural group of project that has 4
the ultimate responsibility for the design of the under-l 5
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Yes.
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7 Okay.
I wasn't trying to be funny.
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8 Do you know where the information came from J
9 concerning the till into which the piles will be driven,
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10 and let me suggest to you the possibility that it came z=
3 Il from a Dames and Moore report.
S y
12 A
Definitely, it was a Dames and Moore original
~
=
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=
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14
?
Okay, that goes back to something like 19697 E
15 A
Ac. e. ro xima te ly.
3 j
16 In determining the bearing capacity of the x
17 c.iles, what kind of c.aramaters do you -- did you obtain a.
t
}
18 from the Dames and Morre report?
What. kind of information N
39 2
do von get?
I A
I think primarily I saw a description.of the 20 21 till, the end values or the results of standard penetration 22 l tests exceeding a hundred blows, and I compared that with 23 my experience with similar material on other projects.
24l 4
Now, I am sure this is so famallar to you, 25 l but it's not that familiar to me -- you said standard s
1 ALDERSON REPORTING COMiANY. INC.
l a
53 i
1 1
penetration tests?
2 A
Yes.
1 3!
G What other kind of advice or paramaters or 4
whatever do you get from the Dames and Moore report 5
that you use in determining bearing capacity of the piles?
s, j
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Primarily standard penetration resistance,
-a e
i 7
description of material, i
2 A
8 G
Are you familiar with any other project in a
9 z.
which a scheme similar to that being proposed for the E
10 service water pume structure has been used?
=
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Yes, it's an underpinning technique that 3
i 12 one would use whenever it's chv.sically cossible to z
s 13 install the Oiles in that manner as opposed to getting
=
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5 14 underneath the structure and jacking them in.
c j
15 4
I get the inference from your answer that it
~
16 is preferable if you have the room to put the piles ie i
N I7 immediately adjacent to the building as opposed to e
3 18 underneath the building, or do I misconstrue your N
19 a
answer?
n i
20 A
Yes, you did misconstrue.
21 Okay.
Tell me.
22 i A
The structure that we are looking at it's i
23 [ 4 combination bomb shelter and pill box in terms of f
a 24 l being very magnificently overdesigned.
i 25 It's overdesigned?
1 ALDERSON REPCRTING COMPANY,INC.
l 1
54 I
A As far as underpinning, people who are experts 2
in this area would regard that structure as an absolute t
13ljoytoworkwith.
4 4
3ecause of its original structure?
5!
.L Yes, it's cuite stout.
Ordinarily, people n
j 6
that are dealing with underpinning, are dealing with i
R i
=
1 7
structures that may be somewhat aged and about to fall i
i 8
A apart on their own, and it makes it a very, very delicate c
9 operation.
A 10 j
- n this case we are' dealing with a new 2
11 structure that's been designed for doomsday tv. e. e loadine.s 3
12 i
and is hence very stout, and when you are dealing with it is i
13 construction stage, it's relatively an ideal structure 3
14 E
to work with.
Consequently, there are a lot of things
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you can do that you might not do in other projects on 16 3
other types of structures.
l
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17 G
Okay.
You indicated that you are familiar l
d b
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2 18 with other orojects on which a similar scheme was used.
h
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i 19 ) Can you tell me -- can you give me an example?
n i
A I would have to go back and review some jcb 21 lists.- There may be maybe 800 or more projects, to i
22 i
- eack out a coucle, but it's not at all unusual -- pile 1
23 ' driving pro j ects i
that involve some difficult soil con-24-i L
i ditions to have scme piles that are rejecued, and that a 25 ' fix has to be instituted, and sometimes that.fix s
1 ALDERSON REPORTING COMPANY. INC.
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1 criving ad acent piles next :o it and strapping on.
i 3
2}I Okav.
ust a moment please.
I 3
1 (Pause) 1 4!
Or. Davisson, I did not understand your use i.
g 5{oftheexpression the piles, or a pile, was rejected.
n I
g 6-A Maybe some damage to the pile after it's N
1
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driven, or at some stage one determines i
n k
3 MS. 3 LOOM:
If I can interrupt, I chink he u
9 2.
was t a a..< in g ac o u t cener cro.7ects.
C 10 5
MR. PATON:
Oh, okay, fine.
Other projects.
z
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II THE WITNESS:
Absolutely.
i 3
y" f-MS. 3LDOM:
He said this scheme would be i
i 13 i
used when --
3 14 g
MR. PATON:
Okay, fine.
u:
15 i
MS. 3 LOOM:
When something would happen.
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Okay, I appreciate that.
s 17 3Y MR. PATON:
(Resuming) j i
5
);8 S
You indicated that you would have to ;ook at
-r*
19 a number of -- hundreds of files to come up with a j
i
(
- O couple of examples.
I am asking for your present J
21
. recollection.
22 i Can ycu recall any example where a similar i
t
,3 ischeme was used?
24 i A
A building in Akron, Ohio, where adjaceni 25 piles were installed to a pile cap, and a needle beam ALDERSCN REPCRTING COMPANY. INC.
i i
30 1
I ! inserted under the foundation and poured on top of the new 1
2 } piles, thereby supporting part.
This is a very similar 3 ' oceration.
4 G
Okay, I'm in your area not mine, but a needle 1
5lbeamwouldseemto indicate that the support was no:
s N
g 6
coming from the side, but was coming from underneath?
n i
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1 In that instance, it was not attached to the
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wall.
I would have to, like I say, go back through these c
9 z.
records to see if we have attached scme to the wall.
10 S
That's what I was re f e rrine. to.
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3 II think of any example of that where the support was a
5.
I2 from the side as co.n.osed to belcw the structure?
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offhand, no.
It would take investigation to g
come up with other projects in which that was done.
I 3
14
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15
?
Could I ask you -- how long would it take you
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A Several days.
a t
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I see.
W I9 2
MS. BLOOM:
Off the record.
I n
t
,O (Discussion off the record) l 2I J
MS. BLOOM:
On the record.
l 22j 3Y MR. PATON:
(Resuming)
- 3 '
l 7
Dr. Oavisson, in a building I think you have
^4 j described as stout, such as the service water strueture,
^
4 25 woulf you expect to find cracks, other than shrinkage i
ALDERSCN REPCRTING CCMPANY. INC.
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37 t
I cracks, -- and apply that to the Midland case, with all 2
you know about the Midland case -- would you be surprised 1
3 to find any other kind of cracks other than shrinkage 4
cracks?
e 5
Pro' ably would.
A c
n
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G How do you determine the difference between e
I
?,
7 a shrinka9e crack and a stress crack?
n i
8 5
A Csually you find a reason for the stress c
9 z-crack in terms of its orientation and location.
10 g
You mean if it's a stress crack, it's in a
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'i 12 z
you it has to be something other than shrinkage, or 13 E_
probably is, or may be?
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14 5
A Yes, and width may be a clue.
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4 Are you aware of the present discussions between !
=
3 the Staff and 3echtel and Consumers concerning the
?
16 a
17 Staff's request for additional borings?
d-5 18 A
To an extent, yes.
=
19 2
4 Are you aware with respect to the service n
20 as they may effect the service water structure?
21 1
Yes.
a
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And do you have an opinion as to whether or i
~3 I acditiinal borings at the i not the staff needs tnose i
'4 i
^
4 service water structure?
i 25 A
Yes, I have an opinion.
i ALCERSON REPCRTING COMP ANY. INC.
58 I
G What is that opinion?
2' 1
Definitely they don't need them.
I i
3 G
Is it your opinion that any information that 4
would be obtained from additional borings in the area of e
5 service water structure would be misleadinc?
-N j
6 1
I have no opinion on that.
n O
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indicated at one point that it would be misleading.
9 Do you recall making that statement?
z i
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A I don't recall.
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3 II G
Would you agree with a statement that it a
12 i
would be impossible that information obtained from i
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g these borings could be of assistance n
5 I4 information on the problems at the service water structure?
4 c_
j 15 A
I have no conceivable use for additional i
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I0 borings at this point.
C 17 1 G
Is that because of the heterogenous nature j
2w
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of the soil?
19 2
A No.
20 G
Why do you say that?
2I i
A Maybe I better retract that.
It could, in 12 fact, relate to that, but primarily.che decision is 23 made that material vill be penetrated and the loads
- 4 Icarried in the underlying till, and at.that point i't ' s
- 5, academic and folly to be wasting money, time,-effort on i
ALDERSON REPORTING COMPANY. INC.
59 I
'that concern when, in fact, there is other informatica 2i that we don't have yet that is much more pertinent.
3
?
You are saying -- are you saying that, for 4
example, if you run a load test, that's not theory, 3 ;tha
's in fact field results?
.4
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1 Absolutely.
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And is much more persuasive than any testing i
8 5
which is subi.ec: to certain e.roblems?
c 9.
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1 Yes.
10 2
All right.
This whole question relates to i
z=
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the degree to which you want to be certain that your 3
i 12 z_
structure is safe.
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Would you agree with that?
14 n
2_
1 I don't follow what it is you are asking me
=
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to agree to.
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What I am saying to you -- I think you in-I t
17 M
dicate there is some possibility that the information t
18 from the borings would be of assistence.
19 l
i I think he changed his answer.
l 0
MS. BLOCM:
No, that's not what he changed 21 f his answer on.
He said the heterogenousness of the soil i
22 ) may be a reason whv. you wouldn't want to do borings.
I 23 ;
MR. PATON:
All right.
Let me go back and i
24 :i ask him --
25 733 3;733g3,
- ,s really the reason that we i
ALDERSON REPORTING COMPANY. INC.
4 60 I
are not using them.
2 3Y MR. PATON:
(Resuming) 3 G
Is your statement that it s impossible tha 4
the information obtained from the borings could be of
+a 5
assistance in vour assessment of the service water
..n
~
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structure?
R
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Ch, no, I will admit there is the possibility
-n 8
one might find some use for it.
It's just not on the
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tacle now.
10 j
G You say you are not able to see one -- you b
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Il are not able to conceive of any use?
m N
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That's right.
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Then your present opinion is as far as you m
14 3
know right now, you can't see any use right now?
u 15 A
That's correct.
s g
16 G
I want to ask you about the current status
^
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l7 of the testing.
Has any of this work -- has the pile d
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9 "s
19 A
No.
n 20 G
So, none of it's been done?
21 A
That's correct.
I 22 l G
At the serrice water structure there is a problem with the soil.
I think you would agree with th'a:.
23 24
-i Do you agree to tnat?
25 A
Yes.
i ALCERSON REPORTING COMPANY. INC.
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(
61 i
1, i
I G
What's the problem?
2 A
The problem is evidenced by an investigation 3 ' made by borings
-- not that I could see from any settlement 4 lof the structure, as for example took place at the diesel 2
5
=enerator.
(
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In the borings the low standard penetration-a 4
4 6
7 resistances were encountered in the fill material, and u
A 8
determinations made by others than me were that no t
9 z.
supporting value would be attached to that soil for 10 design purposes.
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okay.
You indicated that there were low blow a
12 i
counts, is that correct?
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And this indicated a lack of adequate support?
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It indicated to others a lack of adequate
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l i
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Is there anything else you needed to know
=
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I9 g
the probicT -- in order to perform your task?
n 20 x
30, 21 4
And it was a problem because the building 1
22 ' would settle more than permissible.
Would you agree i
23 l with that?
24 I A
No.
25 G
You say no?
6 1
i ALCERSON REPORTING COMPANY,INC.
l
i 62 i
I A
No.
2
?
Why was it a problem?
l 34 A
We were left with a section of the building 4
cantilevered as far as the design goes, and under doomsday i
a-5 loadings, the building is not sufficient as it now 6 I' n
3 a
i stands to handle that.
There would, in fact, be stresses j
,n r
n 7
l developed that are too high and accompanying de:ormations c
1 8
=s so that some support was deemed d2sirable at the canti-C:
9 j
le.ver end of the building.
A 10 5
G If there had been a soil problem at the 2
11 I
g building that would have allowed the -- what is it i
12 to settle 1/100th E
the cantilevered end of the building 13 E
of an inch over fortv. v. e a r s, would that be a problem?
,I E
14 1
5 A
No.
l
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O k a v., that's not a c.roblem?
T 16 B
A No.
i a
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17 G
?
Okay, then you have made some determination that
=
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18 it was a sufficient problem that you had to do something
=
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20 A
No, I did not make the determination.-
21 4
Who-did?
1 22 {
1 Sechtel.
23 ~
G Do you know what criteria they used to 24 i
$, determine?
25 A
No.
I ALDERSON REPORTING COMPANY. INC.
I-
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63 i
I G
You don't?
2 A
Once they had determined that they needed 3' support, then I was asked for methods of getting the 1
1 4 :isupport.
I 51 a
i G
So, Bechtel told you there is a problem, and N
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we want v.ou to fix it, but vou didn't need to know what 3
5 7
criteria they used in determining there was a problem?
n i
8 n
A No.
C 9
j Do you agree with that statement?
10 3
j A
That is correct, no,I did not need to know.
l
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No -- meaning yes.
Okay.
d 12 3
Do you agree with my last statement?
t
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MS. 3 LOOM:
De vou want it read back?
z=
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d MR. PATON:
Read it back, please.
l
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b (Question read)
=
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16 3
BY MR. PATON:
(Resuming)
I
^
i l
y l7 I
G 3echtel told you there was a problem at the E
18 service water structure.
Do you agree with that?
s C
19 5
A Yes.
n i
i' 20 '
4 Do you know what criteria they used to 21
. determine there was a -oroblem at the service water 22 1' structure ?
23 '
1 In detail I do not.
l e4
?
Do you know anything about it.
25 A
Just generally -- knowledge that : might have 1
ALDERSCN REPCRTING COMPANY. INC.
I
64 4
I 1
in other in general that's applied to other soiIs 2, locations.
1 3
Well, what is that knowledge?
4 i
A That the low blow counts were indicative of compressability, and relatively low sheer strengths 6l'andpotentially n
2 I
liquifiable material, and it did not 4
7 look as desirable as one would like to have for this s
i 8
a condition.
o 9
z.
2 Okav.
10 j
1 I would like to add that it was not ny job 3
=
11 j
to study that condition.
l '*
2 q
All right.
Do you have any knowledge of
=
13 whether the building, in its condition when you first 3
14 2
were retained as a consultant, whether in that condition 15 2
any NRC criteria had been violated?
i i
~
16 i
I am asking for your knowledge, j
z e
l i
n 1:7 0
A I am unaware.
p G
18 G
De v.ou know whether underpinning was con-19 8
sidered as an option for the diesel generator building?
n 20 A
I am sure it was thrown on the table also, 21 i
just as I threw several options out for the service i
22 i l
water cumo structure.
1 23 't G
Oc you know why it was rejected at the diesel 24 -
! generator building?
25
'A No, that would be best asked of Dr. Peck and 1
ALDERSON REPORTING COMPANY. INC.
1
'l
a 65 I
'Dr.
Hendron.
2 4
Are there t
3' MS. BLOOM:
One moment.
4 (Pause) s 5I 3Y MR. PATCN:
(Resuming)
N 2
6 G
Are there any pipes running under the service R
i 4-7 ' water structure?
n!
3 A
I am unaware of them.
9 z
any conduits?
O Are there 0
10 A
I am unaware.
These are ice =s that project 5z=!
II would be resconsible
~
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12 G
Are there any pipes running adjacent to the E
i 13 service water structure under the ground?
==
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2_
1 There undoubtedly would have to be.
e IS 4
Do you have any idea what the impact of
=
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. ' ~17 4
the settlement of those pipes?
_=
f I8 A
Well, you are telling me first of all that i
pipes exist, and I guess I agree that some have to exist.
19 t
20 G
I think you told me they have to, right?
21 A
I expect a negligible effect.
22 g
Do you have any responsibility to advise i
23 l 3echtel in that regard?
24 -
,. o.
.s
'S q
Are you aware that there are Category I service 1
ALDERSCN REPCRTING COMPANY. INC.
66 i
I
' water pipelines between the auxiliary building and the I
2 ! service water structure?
i 3l A
I am certain there would be.
1 4 '
G Are you aware that there are Category I g
5, service water pipelines be: ween the diesel generator n
6 I, building and the g
service water structure?
1 A
N o., I was not aware of that.
I'
=
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i 8
5 C
For reinforced concrete structures subjected a
9 z.
- o tensile stresses due to imposed design loads, are 10 5
cracks observable to the naked eye acceptable?
z=!
II A
Yes.
3 12 E
G Obviously, there could be cracks observable to
=
13 '
5 the naked eye which would not be acceptable?
m i
=
14 x
A Yes.
-=
0 15 h
G Is there an ACI or other code that addresses
=
f y
16 what is all'owable width or any other criteria with n
i 17 9
respect to these cracks?
l 6
i I8 A
I couldn't cite it if there is one.
I would 19 j
suggest that you ask these questions of the people who
,t 20 are responsible in that area.
21 C
You are a structural engineer?
22 i A
Yes.
23 G
You may have told me this,.but tell me again, 24 why doesn't a structural -- why don't you have resp ~en-4 25 l
sibility in this area?
4 ALDERSCN REFORTING COMPANY, INC.
I
4 4
1 Of f
I A
Secause project has responsibility for the 2
structural engineering on that building and on the entire 3 l operation going on with that building, which would 4
include this underpinning.
5 g
MS. 3LCOM:
3efore we go on, I want to clarify n
~
2 6
what is ACI?
Just for this deposition purposes, what 1
R s
=
7 is ACI?
n 3
a MR. PATON:
American Concrete Institute.
u
)
3Y MR. ?ATCN:
( Re s umi ng)
=
9 10 E
4 Considering the responsibilities that you do 11 2<
have :or the service watdr structure, if at anv time i
3 12 2
you did observe cracks that you thought were other than i
13 a
shrinkage cracks,-that would effect your deliberations, 1
5 14
?
wouldn't it?
IS b
A Are you saying in the service water pump
=
16 i
structure?
=
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G Yes, sir.
=
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4 i
19 t
j ask a question about them, certainly.
l 20 4
In a reinforced concrete structure, is there
)
21 any width of crack that you would consider to be un-J 1
22 r acceptable or that you would consider something other l than a shrinkage crack?
'4 J
A I have not given that situation any thought, 25 and ordinarily in any observations of cracks, I don't f
i ALDERSON REPORTING CCMPANY. INC.
I 63 I
measure the width.
I as afraid I don't look at them in 22 those terms.
}
3l Also, in deliberations with regard to such
}
4 things, I have available to me people who are specialists 5
g a in concrete, reinforced concrete, that I would use as s
1 g
6 consultants to me rather than relying on my own background.
R 6
=5 7
2 I want to ask you a very similar question to
-nj 8
what I asked you a minute ago.
J 9
For reinforced concrete structures subjected z.
O y
10 to sheer stresses due to imposed design loads, are z=!
II cracks observable to the naked eye acceptable?
i 5
12 5
MS. BLOCM:
I want to object to this question
=
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I think he just said for the past
=
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14 fifteen minutes that that's not his area of expertise, t
I
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15 and I may be I don't think I am misstating him that
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j 16 he has not been involved in that.
t I7 MR. PATON:
I think that's a fair statement.
M
}
18 I'm getting ready to -- I have just a few more questions.
l 19 l
s I understand what you are saying.
2-20 THE WITNESS:
If I may respond just a little
[
t 2I bit to that.
22 MR. PATON:
Of course.
l 23f THE WITNESS:
A sheer is a measure of diagonal
- 4 ;' tension and is definitely a concern to structural en--
25 gineers, but to respond a little bi Oc'the general i
i.
ALCERSCN REPCRTING COMPANY. INC.
L.
69 i
I I
I ?line of questions with regard to this project, I do noe 2,have the structural responsibilities, cnd while I may 1
3 ' develep -- make notes or observations, and pass it on --
l 4,I am not the one that is responsible for this area.
S 5
If I were in fact responsible in this area N
~
2 6, en the structures, I would engage the services of someone 7
to help me with it.
8 MR. PATON:
All right.
Fine.
9 THE WITNESS:
Which I have not done since I i
.~
g 10 4 am not the responsible person.
z 11 MS. 3LCOM:
Ceuld we go off the record?
4 i
3 E
(Discussion off the record) 32 i
2 13 BY MR. PATCN:
(Resuming) 5 2
5 I4 G
Dr. Davisson, if there was a crack in the
_=
j 15 service water structure that extended through the wall, a
g 16 like from one side to the other, would you conclude a
N II tha: that was a stress crack?
Eso 18 MS. BLCCM:
What wall are you talking about?
i s
I9 g
MR. PATCN:
Any wall.
n 20 THE WITNESS:
Probably, however, again, I have 2I ;, not observed such a crack myself nor am I responsible 1
22 i for concern over that, i
'3 3Y MR. PATON:
(Resuming) 24
?
Okay, have you observed cracks in any wills of anv. Catac. cry I structures at a n v. nuclear facility
.S ALCERSCN REPORTING COMPANY. INC.
70 I
other than Midland?
2 1 g
r 333.t recall any.
i 3,
?
Ckay.
i 4'
1 Again, that would not be my responsibility.
[-
3[
Dr. Davisson, I want to show you a document n
I 2
6 '; t h a t is -- that has the words " crack mapping" in the I,
-n=
I 7 ' lower righthand corner, and I will suggest that it is
?9!
3.from -- Figure 62 of Interim Report 5 of MCAR 24
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9 l which is car of the 50.54 (f) responses.
z 10 MS. 3LOCMt Before we go on, could we have that 5z=!
II marked as an exhibit, please?
m 12 i
MR. PATON:
No.
_=
j 13 MS. BLOOM:
Why not?
=
o 14 2
MR. PATON:
Off the record.
_:j 15 (Discussion off the record)
=
E I6 MR. PATON:
All right.
I am going to mark that a
17 3
as Deposition Exhibit No. 2 Davisson, and today's date, f
=
}
18 which is January 14, 1981.
"m 19 (The document referred to was a
20 marked Davisson Deposition 21 Exhibit No. 2 for identifi-l 22 i cation.)
t 23 i.
3Y MR. PATON:
(Resuming) 44 s 0
I show you that documen and ask you if you 25 have ever seen that before?
ALDERSON REPCRTING COMPANY. INC.
71 i
I A
No, I don't recall ever looking at this before.
2' G
Okay, let me ask you this:
I am asking you i
3: to assume that the information this document purports to 1
4 represent is accurate so you are not assuming any re-i 5
2 sc.onsibility for the accuraev. for that.
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I am asking you to assume it's accurate.
R 1
7 Can you draw any conclusions with respect to cracks from n
i 8
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that document?
e 9
?.
A Not withcut studying it.
I guess I am pleased
'i that somebody is looking a: the cracks and mapping 10 s
h II them and all that, but again, this is not an area I 3
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12 was asked to look into, nor am I responsible for it.
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okay.
Dr. Davisson, let me ask you to assume l
U 14 I
that there are cracks in the service water structure,
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again to the document that we just looked at.
f j
16 2
17 l
Is there any way for you to know now wha ~
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18 impact the underpinning will have on those cracks?
19 2
A To a limited extent, yes, n
20 S
What can you say at this point?
i 21 A
Well, to the extent that the soil that has j
22 I been deemed inadequate has allcwed the cantilever I
"3 portion of the structure to settle.
There's a certain i
24 pattern of cracks that one could anticipate might 4xist, 25 and jacking the loads into the underpinning piles i
ALCERSCN REPORTING COMPANY. INC.
-n au b
i i
that motion, reverse it, and would I
bwilltendtocounteract 2
cend to close those cracks that arise because of that, j
3 !
Now, if there are other cracks fer other reasons that are not related to possible settlement of 4
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the cantilever portion, that's an entirely different 5
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6 su,cject.
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For example, shrinkage cracks probably would
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n not close?
z-A That depends on whether they are in the path 9
g of the motions that would take place when loads are 10 There certainly would be a group II jacked into the piles.
5 i
that would not be expected to close.
12
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i 13 If cracks begin to occur during the under-i 2_
4 i.
3 pinning process, do you have any criteria that you would x
14 2
15 use to react to that situation?
A That would be the responsibility of project i
s' 16 t
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17 I
e structural.
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Then the answer is that you don't have any G
13 I
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criteria that v.ou would plan to use?
19 a
1 No.
21 MS. BLOOM:
I will make it very clear -- that's 22 I, because he said it's not his responsibility. to develop l
l i
I 23 i do anything in regard to those cracks.
l 1 on --
24!
THI ~4*TNISS:
That's correct.
t
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Okay.
l I
ALCERSON REPCRTING CCMP ANY iNC.
73 t
I I 3Y MR. PATON:
(Resuming) 1 2 {4 4
When you receive information from Bechtel, do 1
3 l you receive it from Dr. Afifi?
1 4!
A Yes, directly or at his recuest.
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S I shew you a letter dated March 25, 1930, w
g 6
from Sherif Afifi addressed to Dr.
M.
T.
Davisson which o
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7 I will mark Deposition Exhibit 3,
Davison, 1/14/31 and
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ask you if you have seen that letter before?
J 9
(The document referred to was I
10 marked Davisson Deposition E
I II Exhibit No. 3 for idenuifi-3 12 cation.)
j I
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Yes.
I
=
3 14 2
BY MR. PATON:
(Resuming) 15
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S Along with the technical specifications that
,6 p
they sent attached to this letter, is it correct tha' k
II theY did not send the concrete specifications, and let
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e I9 i
1 There was an instance where that occurred, 5
i 20 ' and I don't know if that was the date on which'it 21 occurred or not.
22l G
All right.
Let me show you a document 23 entitled March 29, 1930, " Memo from M.
T.
Davisson to i
24j 3,
g, gftft,, the last sentence of which reads:
" Note 25 '
that I did not receive the concrete specification for i
ALDERSON REPORTING COMPANY.-INC.
l
76 l
1 review."
Does that refresh your recollection in that 2
regard?
3 >i MS. 3LCCM:
Could we have that made an 4
exhibit too?
s 5
MR. PAToN:
If you insist.
s 3
6 MS. 3LCOM:
Yes, I do.
a
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7 THE WITNESS:
That probably was the instance.
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MR. PATON:
All right, I am marking the u
2 9
document that I just referred to dated March 29, 1930, as z,
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10 Deposition Ixhibit 4,
Davisson, 1/14/31.
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4
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3 11 (The document referred to was
<3 12 marked Davisson Cecosition z
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13 Exhibit No. 3 for identifi-
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14 cation.)
4 E
15 3Y MR. PATON:
(Resuming)
=_
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Do you know why they did not send you the 7
16 A
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d 17 ' concrete specifications?
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18 MS. 3 LOOM:
Off the record.
=_
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19 (Discussion off the record) t
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3ack on the record.
i 21 THE WITNESS:
To answer the cuestion, the 1
^
ZZ concrete specifications that I mentioned in a memorandum 23 was referenced in the specification I was reviewing, 24 l and for the sake of completeness, I thought I shour'd see 25 the referenced. specification also, so I requested it.
l i
ALOERSON REPCRTING COMPANY. INC.
4 75 1
3Y MR. PATON:
(Resuming) 2 G
By the referenced specification, you are 3 italking about the concrece specification?
i 4
1 That is correct.
5 o
G Did you need those for your review?
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Yes.
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Do you know why they didn't send them to you n
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1 Probably an oversight, since it was merely 5
10 a referenced spec...:: cation.
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4 Okay.
3 12 i
MS. BLOOM:
Off the record.
r 4
13 E
(Discussion off the record) i i
3 14
?
MS. BLOOM:
On the record.
15 h
BY MR. PATON:
( Re s uming)
=
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When Dr. Afifi sent you the technical speci-A i
fications for furnishing, installing, and testing l
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what did he want you to do?
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Review them as I recall.
21 4
Okay.
22 4 1
And comment.
23l 2
And he indicated in his letter that we will be installing he pipe piles within two to three weeks.
'S Do you recall that?
a ALCERSCN REPORTING COMPANY. INC.
76 1
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i I believe it A
That we will install a pile 2,
was a test pile.
1 3
4 Did that give you adequate time to perform 4
your review?
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For the work that was to be performed a: that
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Commission in this case, in your professional judgment 9
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concur in the remedy that Bechtel is proposing to use i
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at the service water structure?
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Within thw limits of the responsibility that 13 l
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NRC, yes.
F 15 E,
O 3y the limits of the responsibility -- are 1
16 these matters you have discussed on the record already l
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17 O.
t o d a v. ?
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A Yes.
U 19 i
G Are your standards of review for Sechtel and l
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20 the NRC the same?
4 21 l J
A Yes.
f.
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g Dr. Davisson, there is a reference in Deposition 23 #! Exhibit 3 -- in fact the third paragraph -- I am reading:
24 ] If all goes well, we will be installing and testing.the i
25 l
pile within two to three' weeks.
At'such time we would i
ALCERSON RE?CRTING COMPANY. INC.
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I appreciate having your representative attend the in-t 2
stallation and testing."
4 3'
Did that testing ever take place?
i 4i A
No, no test was performed.
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Do you know why?
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Yes.
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Why?
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A Secause 3echtel was to supply a pile meeting u
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G Okay.
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I4 meet our requirements, and hence that pile was not tested.
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Bechtel and mine.
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Okay.
You said somebody cobbeled together a
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Yes.
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Who did that?
4 22 !
A 3echtel's field forces.
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Project?
24 :
A You better ask Sechtel.
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Ckay.
Have they to date ---have they tested i
ALCERSCN REPORTING CCMPANY. INC.
73 1
the pile?
2 I
l A
No.
4 i
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4 Are they still having difficulty getting the 4
right kind of material?
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Do you know why they haven't n
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Do you know why they have not
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A No.
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C Okay.
I don't understand why, considering l
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. your position and your responsibilities 13 i
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this test yet.
Could you respond to tha:?
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A I think you would have to ask Bechtel project.
T 16 3
G Have you ever asked them within the last ten a
F 17 d-months when they will perform this test?
7 18 l
A I am sure I have inquired of Afifi.
19 j
4 But do you recall whether you have inquired?
A I don't recall specifically, I just feel
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Okay.
What did he tell you?
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Nothing definitive or I would.be.able to 24. repor: it.
i 25
?
Okay.
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ALDERSON REPCRTING COMPANY. INC.
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- Again, he would have to inquire of project.
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S So, you presently have no knowledge as to when I
3 j:here will be a pile tes:?
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A No, I de act.
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Have you reviewed the quality assurance n
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A To my knowledge such a manual does not exis:
a 9i z,
at this time.
C 10
?
Is that within the secpe of your responsibility?
II A
Yes, I as certain it will be.
3 12 i-G Do CA precedures exist at this time?
A In general yes, at the clant site.
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CA c.recedures s=.ecifically with respect to i
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the installation of piling at the service i
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16 3
A No, they do not.
a
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did you not?
n i
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A Yes, and it's still not complete.
21 G
Okay.
Is it correct that the piles at the 22 l service water c. ume. structure will be tested individually i
'3 l' o
150% of the load?
i 24l A
It's my recollection that it's 150%.
a 25
?
Is it correct tha: there will be no proef ALDERSON RE.=ORTING COMP ANY. INC.
s' q
80 i
I loading of the piles as a group?
2 A
That is correct.
3j 4
Can you tell me why?
t 4
A That would require a considerable reaction, l
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unnecessary.
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Am I correct that you cannot conclude that if s
8 the individual piles were tested to 150% that the group t
9 would not test to 150%?
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I'm afraid I don't understand your question.
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All right, let me try again.
m N
12 Assume that you do what you intend to do in 5
13 chis case, and that is to test individual piles to i
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5 I4 150% of the load.
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15 From that can you make any conclusion with
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z
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17 test to more or less than 150% of the load?
s i
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Yes.
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19 G
'dhat?
20 A
I would conclude that the group capacity would l
21 j equal sum of the individual capacities.
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22 !
I might also add that we really don't have j
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23, normal pile groups.
j 24 G
You mean because they are separated by rome a
25' distance?
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i ALDERSON REPORTING CCMPANY, INC.
i 4
t 31 3
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1 1
A That is correct.
l 4
2 G
Are there any plans to have a person monitor i
3 'the piling installation at the service water structure?
4 A
Yes.
g 5
G Where does that requirement appear?
j 6
A
- am not sure.
I know that if there is any R
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7 work done on those piles, myself or my representative nj 8
v'.11 be there.
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9, G
I show you a document which I will mark as i
10 Deposition Exhibit 5, Davisson, 1/14/81, and I will Z
11 show you -- you can look at all of this document you want 1
j 8
f 12 to.
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14 marked Davisson Depos_ tion l
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cation.)
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d 17 MR. PATON:
This looks like it's about twenty I
w i
pages long, and I show you the names at the bottom --
5 18 w
19 M.
T.
- Davisson, C.
H.
- Gould, A.
J.
Lougheny, and R.
3.
Peck.
ai g
n 20 The words at the top are:
"The consultants 21 ) request the answers to the following."
f 22 I Let me ask you if you have ever seen that before.
23,
MS. 3 LOOM:
3efore we go on, can we date it 24j and say that.it's handwritten?
t 25 MR. PATON:
The document _that ! have described l
1 ALDERSON REPORTING COMPANY. !NC.
32 i
i I ' has a cover en it which has " Consumers Power" in heavy 2' letters on the top righthand side; it says "To File from 3 lT.
C.
Cook" and it's dated August 10, 1979.
i Now, there are a number of other documents 4'
a 5
attached to it, that is just the cover, but about two-thirds N
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of the way through the document is the particular page R
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I am re: erring you to.
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3Y MR. PATON:
(Resuming) 2.
2 I will ask you if you have ever seen that before?
9 0
MS. BLOCM:
Would it be okay if we include at 10 E_!
II the beginning that it's a handwritten document 3
12 E
dated June 29, 1979?
=
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The handwritten portion of the l
=
3 14 document 2
w=j 15 MS. BLOOM:
Just be careful -- it's a long
=
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A f
N I7 MR. PATON:
Although there is several dates A
l
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18 included in the document, it appears that the handwritten
_+"
3 portion of the document is dated June 28, 1979.
19 n
20 THE WITNESS:
Your question again?
2I BY MR. PATON:
(Resuming) 4 My question is have you ever seen that document 22 23 before?
I 24 '
1
.A Yes.
i 25l Did you obtain he information you requested 1
i ALDERSON REPORTING COMPANY. INC.
t 83 a
f a
1 in this document?
2 A
I did not.
I might add that that document is 3,ja summary of several consultants input.
7 Was this information requested for one of 4
5
-he other consultants as opposed to yourself?
e M
j 6
A Yes, Mr. Gould, i
l E
6 7
0 Am I correct that none of these three items n
8 requested on your behalf?
were S
MS. 3LCCM:
Why don't we read the three items?
9 Z
10 MR. PATON:
Yes, Let me do that, and it will i
z 3
11 be easier, and we won't be looking for pieces of paper.
3 I2 E
MS. BLOOM:
Please do.
m j
13 3Y MR. PATON:
(Resuming) j i
M j
g I will read them for the record, but you l
14 i
1 j
15 have read the three items that I referred to you, is j
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16 that correc*'
I w
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17 A
Yes.
[
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0 And your testimony is that none of these were l
j 18
-8 19 g
requested on your behalf?
t n
20 A
At that time they were not on my behalf l
21 or anything that I was responsible for at that time.
4 1
22 i G
Did you request them later?
23,'
t 30, 24j g
Okay.
You said at that time, and I wondered.
25 A
It has to do with the aux building in which I
ALDERSON REPORTING CCMP ANY. INC.
34 1
I I
Mr. Gould was primarily responsible for.
2 okay, and you have taken over from Mr. Gould 3 l his responsibilities?
I 4
A Part of it.
s 5
G The part that you took over was the electrical nN j
6 penetration area and the feed water isolation valve pits?
R a
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I have to admit I am not clear on it at this
/
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point in time.
That's a relatively recent change and u
9 there has not been much activity.
?
10 t
G In fact, he turned this over to you somewhere z:
i II around August of 19807 l
3 j
12 1
Well, he gave it all back to BechteL and
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g geotech asked me to consult with them on certain portions i
t I4 of the work that hehaddoneorwouldhavebeenresponsible!
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15 for if he were continuing.
a How much time have you spent on that since i
16 A
17 H
August of 1980?
t 3
18 A
I doubt if I spent a day.
9 I9 g
0 Okay.
n r
20 MS. 3 LOOM:
Can we read those items?
II MR. PATON:
Yes, I am going to.
22 l 3Y MR. PATON:
(Resuming) i 23
?
Do the best you can in telling me what date I
e 24 it was that sechtel turned this responsibility ovef to you.
25 MR. 3LCOM:
Responsibility of the office?
i ALDERSON REPORTING COMPANY. INC.
~
95 i
I MR. PATON:
What responsibilities you took over.
THE WITNESS:
Well, I am unclear what respon-l 2
3 r ibilities I have on that at the moment that would have s
4. occurred in August or September in 1930.
5 MR. PATON:
Okay.
I want to now read for the a
n 5
0 record the three items that are listed on the page that I
-1
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, have asked Dr. Davisson to address.
I n
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n "1.
Static defection" 3
J 9
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THE WITNESS:
Deflection --
2 10
'J MR. PATON:
It reads " defection," and I would 3_!
II suggest the possibility that it should read " deflection."
s 12 i
" Configuration of auxiliary wings under full l
a cantilever treatment, cracked and uncracked.
l' 13 l
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B 14 1
3_
"2.
Seismic analysis of auxiliary building with 15 h
deflections configuration, accelerations at each floor I
g 16 level, edge forces due to rocking, horizontal forces to n
17 d
be resisted and locations.
l 18 i
"3.
Analysis of auxiliary' wing stresses and 19 3
deflections with 1500K and 3000K each at EW ends."
n O
MS. BLOOM:
Once again, can we make it clear 2I.that Dr. Davisson did not request that information at i
a 22 1; that time?
23 '
i MS. PATON:
- Okay, 1
MS. BLOOM:
Do you want to take a break'now 24 '
25 for lunch?
ALCERSCN REPORTING COMPANY. INC.
4 4
36 I
MR. PATON:
Fine.
2 (Whereupon, at 12:30 p.m.
the deposition in the 3-Iabove-entitled matter recessed, to reconvene later this 4 isame day.)
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_A _F _T _E _R _N _O O
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3 i SY MR. PATON:
(Resuming) 4 G
Dr. Davisson, how many times have you talked e
5 to Mr. Gould since August of 1930?
9 j
6 A
Perhaps once.
R
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G You testified prior that GA manual for pile l
8 installation does not exist, is that correct?
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A That's correct.
I 5
10 '
4 When do you estimate that a manual will be E
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11 developed for a QA -- a QA manual for installation of piles?'l 3
12 i
A I have no control over that, just as I have
=
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g performed.
By way of explanation, the contractor who E
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15 aventually drives the piles will be looked to as the i
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16 author of the QA - QC operation in conjunction and in x
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17 coordination with Bechtel's procedures, and it is clear i
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18 ' that considerable effort will have to be put into that c
s I9 when it occurs.
A 20 G
Okay.
It's safe to say that that will be at 21 least several montha away?
22 i A
I think so.
l.
23) 4 Do you consider that the proposed remedy of 3
24 the service water structure is a positive solutton?
15 A
I would like for you to define what you mean.
1 l
1 1
ALCERSON REPORTING COMPANY. INC.
l L
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by positive solution.
2 G
I was going to ask you that.
I have a 1
3 ! reference to it, and I think it may have come from fou.
1 4 *Just give me a second.
5 j
A All right.
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6 (Pause)
R 7,
I need something called 9-A.
I want to show
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you the next to the last page of Deposition Exhibit No. 3 1
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10 that is entitled " service Water Structure," and the first l
Z i
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II i
sentence is:
" Service water structure underpinning with l
3 12 ; driven piles and the corbol is a positive solution."
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I will ask you if you have ever seen that l
13
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before?
15 2
A Yes.
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I0 Is that'your writing?
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17 I
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Yes.
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3 18.
G Can you tell me what you mean by positive 19 i
solution?
n
- O A
In the context in which it is used here,
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t the ciles can be driven to have a certain load carrying 21 22 l capacity, and the portion of that capacity that we wish 23 to have jacked into the structure can be installed.
I 24 i MR. PATON:
Would you read that back, please?
25 >
(Answer read) 1i ALDERSON RE.*ORTING COMPANY. INC.
1 l
39 i
I 3Y MR. PATON:
(Resuming) 2 4
Have you reviewed a seismic analysis of the 3
service water structure as underpinnec -- as proposed 4
to be underpinned?
e 5
x go, N
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2 6
Do you -- is that within the scope of your n
I 7, responsibilities?
I' n
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No.
9 4
In the course of your consulting 3echtel with
?
10 respect to the proposed remedy at the service water z
Il structure you do have knowledge of seismic loads, is 33 12 i
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that'~ correct?
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That is correct that I do have certain input
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I4 information that may be used by project in making its
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4 Can you tell me why you would not review the a
I 17 seismic analysis of the structure?
u.
18 A
No, I cannot.
o 1
s 4
Is the capability of the piles within the 19 a
20 seismic loads within your responsibility?
21 A
Yes, within certain parts of it.
i 22 l 4
What parts?
23l A
Load carrying capacity, perhaps portions of i
24j the deflections.
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l 25 c
All ri:ht.
You have cart of the responsibility
)
1 1
l ALDERSON REPORTING COMPANY. INC.
i 90 l
I for capability of piles under seismic loads.
Do you knew 2
who has the other part?
3 A
Project structural.
4
?
And you said part of deflections.
The other 5
part of deflections is for project structural?
n
~
6 e
A Yes.
n i
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7 4
What criteris do you use in your assessment i
8 A
of the seismic deflection of piles?
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?-
A No criteria.
I do not have any criteria, 10 g
nerely furnish information as to what the stiffness of
=!
II the oiles might be under certain conditions.
That is 3
12 E
input information used by project structural for their 13 analysis in which the deflections are output along with i
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o t.ner thtngs.
e:
15 t
4 Do you have to know within the scope of your i
resconsibilities what the safe shutdown earthquake is?
j j
16 s
i 17 t
d A
No, I could do what I am doing withou-t
=
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i
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19 j
G Are there sandy soils under the service wate-I l
- 0 I l
structure?
i 21 i
A The borings show that there are.
l
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22 l O
In the event of an earthquake, is it possible 23 l that they would liquify?
l 24 1 4
A Yes, it's also possible that they would not.
25 '
G Ckay.
In the event that they did liquify, I
i i
ALCERSON REPORTING COMPANY. INC.
L
f 91 i
I I
would lateral drag forces be i= posed on the service water i
f 2: scructure?
3 i A
I don't think I know what you mean.
?
Would lateral forces be imposed on the service 4
j g
5 water structure?
"n 5
0 MS. BLOOM:
On the structure?
R*
7 i
MR. PATON:
Right, that's what I said.
l i
8 THE WITNESS:
I'm afraid I don't understand n
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your question.
Can you try it agein?
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10 3Y MR. PATON:
(Resuming) 5
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In the event of liquifaction, would it be m
12 '
i possible for the fill around the service water structure
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T E
I'd the walls of the service water structure?-
$j 15 It would be highly unlikely that there would i
A 1
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g 16 ' be any significant movement of the location at the piles.
m 17 3
MR. PATON!
Would you read that back, please?
=
18 (Answer read) 19 2
3Y MR. PATON:
(Resuming) a 0
I asked you about the walls of the service 20 21 and I understood your answer to be it j
water structure, 1
22 l would be highly unlikely that there would be any movement
[
l 23 l in the location of - the piles.
You mean on the walls?
i 24 j A
At the location.
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?
At the location.
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ALDERSON REPORTING COMPANY. INC.
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i 92 i
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A Right.
I 2,
the top j
MS. 3 LOOM:
I am not sure the memo i
3 was just the thing that was introduced into the record 4
as Exhibit 4.
I am not sure the rest of the exhibit was a
5 marked into the record.
i H
~
6 MR. PATON:
Let's delay that for a moment.
R R
7
- : think I am going to get into the attachments and then I N
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n will do that.
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MS. 3 LOOM:
All right.
j 10 j
SY MR. PATON:
(Resuming)
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C Dr. Davisson, you said a minute ago I believe l
fI that it would be highly unlikely that there would be
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any movement of the wall near the pile from the -- resultingt n=
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s I
I asked you would it be possible in the event l
I 16 of liquifaction for the fill around the service water i
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structure to move toward the pond excavation causing l
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19 '
j and I think you said it would be very, very -- or highly I
0 unlikely that that movement vould be felt in the walls l
t 21 near the piles, is that correct -- and I don't mean to j
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l
'mischaracteri e.
I 23 A
I don't think you have accurately -- repea:
i 24 l
your statement.
25 g
Could you tell me what's incorrect about i:7 I,
1 ALDERSON REPORTING COMPANY, INC.
1-
93 l
l I
A You are talking about the soil scving toward the walls or something.
2 3
G I don't think I said that.
4 MS. 3LCOM:
Why don't we have the question c
5 read again then?
9 i
j 6
(Cuestion read) l R
E 7
THE WITNESS:
I think your earlier question 8
asked about the soil moving against the piles, not the l
0 i
U 9
3.
wall.
10 MR. PATON:
I don't think -- I read the same E
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3 II : question, f
3 j2 E
I will just start all over again.
=
l 13 gee.s go off the record for a minute.
S 14 2
(Discussion off the record)
E 15 g
MR. PATON:
Okay, on the record.
l
=
E I6 SY MR. PATON:
(Resuming) s N
I7 0
In the event of liquifaction, would it be I
l
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18 possible for the fill around the service water structure c
i 6
I9 g
to move toward the pond excavation causing fricti-on on l
"O t
the walls of the service water structure?
i 21 A
Eighly unlikely, and if it did occur, irrelevant.
22 G
So that you have not taken this into account?
23 ]
A That's not my problem.
l 24l1 I
0 Whose problem would that be?
25 i A
Project structural and back to geotechnical
{
.4 ALDERSON REPORTING COMPANY. INC.
l 94 I. hat's act what am involved with.
2l
?
Are the piles being designed for lateral leads?
f 9
3; A
They can withstand sc=e lateral icads, but 1
4 lit's not intended that they have Oc have either lateral
}
g supper for their integrity, nor am I aware of a icad 5
n 2
6 alcng their side that they are being designed fer.
7 4
s it your opinion that there is no seismic 8
event that could impose a lateral lead en the piles?
e 9
A No, we can always sche =e.up an event that would.
z 10 2
- dare sav we'd have a lo: cf.proble=s at. Midland and z=
3 II in the United States if that ever cccurred.
3 12 '
i 3
Ckay.
I think you construed my questien, and
=
13 5
=aybe rightly so, as is it possible, but are the piles j
g going to be designed to withstand any lateral leads f
3 14 i
e 15 t
from any seis=ic event?
e x
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A Yes, any relative deflections that sight
=
17 I M
take clace between head and base --
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"s 19 A
Any relative deflections that might take n
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place between head and base would induce loadings in l
20 2I the pile.
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4 99"g 3
What seismic leads are the piles going :0 be i
13 i designed :
withstand?
- 4 '!
A Scmewhere in sc=e of the dccu=ents there are 25 sc=e numbers tha: project structural has cranked off as 1
ALCERSCN REPORTING COM,8 ANY. INC.
95 l
l t
1 to what the dynamic increments are.
I don't recall l
i l
2 what they are off the top of my head.
j i
3*
a Is that information that you need in your 44 assessment in your work?
e 5
A Yes.
n i
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4 What do you need it for?
R 7
A Cause I have to knew what the piles are to be
~n!
8 installed to resist, i
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9 G
When did you get that information from 3echtel?
z.
10 '
A The most recent information I had was the I
1 li 11 middle of December of 1980.
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12 4
I show you a document that looks like it's
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f 13 about fifteen pages; it's an attachment to a document that a
5 l'8 has been previously marked Deposition Exhibit 4, which j
n i
appears to be a note from you to Dr. Afifi.
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15
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j 16 The attached document is entitled " Technical I
Specification for Furnishing, Installing, and Testing II l
l c
3 18 Closed End Pipe Piles."
3 I
5 m
MS. BLo0M:
Is there-a date?
I 19 a
l 20 MR. PATON:
There is a date, and my guess is j
21 that the date is October 21, 1979, it's very hard to 22 read.
23 BY MR. PATON:
( Re s umin'g) l g
I will ask you if you have ever seen thst l
24 l
(
25 l document before?
l 1
i j
ALDERSON REPORTING COMPANY. INC.
96 I
i i
I I
A Yes.
I 2
Can we go off the record?
i i
4 3t MR. PATCN:
Sure.
Off the record.
4 (Discussion off the record) c 5
3Y MR. PATON:
(Resuming)
E 5
0 Dr. Davisson, I show you another document that i
R
- 5 7
I will mark Deposition Exhibit 6, Davisson, 1/14/31.
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3' This appears to be thirty or thirty-five pages.
This one I
9 is labeled " Technical Specification for Furnishing, z.
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10 Installing, and Testing Closed End Pipe Piles," and there E
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i Il ' is a handwritten note on the front of it from P.
K.
m 12 i
- Chen, C-h-e-n, dated December 3, 1980.
3 l
13 5
I want to read the handwritten note on tho il
=
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front:
" Tom:
This is the final spec to be issued for
=
[-
15, bids.
Please review as soon as possible.
I will call 1
=
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i6, you to find out what is your comment and also the date i
l
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II of the meeting to discuss the spec if necessary.
Thanks.
I i
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18 Call me if you questions."
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19 (The document referred to was i
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20 '
marked Davisson Deposition 21 Exhibit No. 6 for identifi-22 cation.)
23 3Y MR. PATON:
(Resuming) l 24 G
Have you seen that document before?
25 f A
Yes, and I think you may have given-the wrong dade l
i i
ALDERSON REPCRTING COMPANY. INC.
I
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97 i
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4 Okay.
I see 12/9/80 on there.
Is that incorrect?
2 A
I thought you said
'31.
3
?
Oh, :. f I said that, I would like the record 4
to show that's an error and it appears to be December 8,
i 5
n,
- 1930, n
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A 12/3/80 is the date of the handwritten note.
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7 4
Okay.
Do you agree with Mr. Chen's comments c
A 8
that this is the final spec?
l 0
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9
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A No.
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G okay, why don't you agree with that statement?
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well, that's why we had the meeting.
It was 3
1 12 i
to discuss.
j 13 g
This is not the final spec?
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s A
No.
t:
15,
a Did you attend the meeting that is refer ed to
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16 here?
N I7 A
Yes.
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a What happened at that meeting?
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A We went through that specification.
People 20 from project, geotechnical, and'a gentleman from Mueser-I.
Il Rutledge firm was there.
were there any adverse comments l
22 4
Nhat was 23' or any opinions that indicated that this needed to be t
6%4 4
revised?
25 l 1
Yes.
L ALDERSON REPORTING COMPANY, INC.
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s.
98 1
G Who made those comments?
2 MS. BLOOM:
Clarify what it is -- opinion on 3, revision or whether they were adverse comments.
t 4
MR. PATON:
I did ask two questions of you.
e 5
I'm sorry.
A j
6 THE WITNESS:
They were probably both.
There R
7; were comments thrown out and someone said delete this, I
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8 and if you want to accept that as an adverse comment, it's
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an adverse comment.
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10 BY MR. PATON:
(Resuming) 3 h
11 G
What's the present status of this document?
a Y
12 A
I am operating under the assumption that
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13 project is reworking the specification based upon the l
a 5
14 comments they received at that meeting.
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15 G
Tell us any comments that were made at that j
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17 MS. BLOOM:
Aav comments?
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MR. PATON:
Yes.
I assume he is not going to i
18 i
19 ' tell me g
M 20; MS. BLOOM:
Any comments about that l
21 MR. PATON:
Any comments with respect to this j
3 i
22 document.
L 23 THE WITNESS:
There were several that are 24 written in the margin of that document that I made~ and 25 l there are innumerable comments that other people made that !!
I ALDERSON REPORTING COMPANY,INC.
i L_
s 99 l
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1.may or may not have marked in the draft, and the contents l
2 of which I frankly don't remember at the moment.
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BY MR. PATON:
(Resuming) 4 G
Okay, can you remember any of the comments e
5 that were made by you or anyone else with respect to n
M i
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this document at that meeting?
E i
7' A
Mine are in the margins.
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Okay.
I want them.
Is the only we are going l
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to get them is to go through the document?
10 1
That's right.
I would have to look at the 3
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3 Y
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Well, as a matter of fact, yes.
Are the E
are these all yours?
j y
13 comments that are written in here
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On the original I believe they were in red,
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16 G
Okay.
Would you help me out?
I don't have i
1 17 is that your comment?
I am referring to U
any way to a=
18 page four.
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MS. BLOOM:
Cf Exhibit 6?
5 MR. PATON:
Yes.
20 '
l 2I THE WITNESS:
Yes, these look like my comments, j
22 I
yes.
i 23 3Y MR. PATON:
(Resuming) l I
24 G
What is that comment?
25 l I
A It's questioning the spec on the reinforcing I
i l
ALDERSON REPORTING CCMPANY. INC.
b 100 e a 1
. bar and whet'~.er or not there was a redundancy of the wording, l
21 j
ef the spec.
3 G
Was there any resolution of that item?
4 A
No, there was a comment that structural was I
a 5
to take and work with it and resolve.
n s.
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Okay.
Tell us about your next.
Is that word e
R R
7 "whv"?
Is that your comment?
t e
M i
8 n
A It has a plate, closure plate, that's flush l
g.
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9 with the pipe and I raised the question as to why j
I 10 j
somebody stuck that in there.
t I
5 11 '
i t.at item?
g Was there any discussion of 3
d 12 z_
A Yes.
1 13 C
What was the discussion' 3
14 A
Well, I found out who put it in there -- the e
9 15 2
Mueser - Rutledge people.
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Did you find out why it was put in there?
s 17 d
1 They thought it would add to the capacity of
=
5 18 the pile.
19 3
g Did you agree with that?
i n
20 A
It didn't matter to me one way or the other.
i 0
Is that going to stay in there as written?
I 22 A
I don't recall how that was resolved.
It was I'
i not considered that important an item.
l i
23 1
l l
S Is that something project is working on?'
24 25 l
[
l A
Yes.
i i
l ALDERSON REPORTING COMPANY,INC.
i
s 101 s
i f
1 g
Would you tell us what your next comment was?
i 2
A On page five:
"We have considered several 3 l alternate pipes with diameters and wall thicknesses, 4
and depending on certain selections that are finally I
e
- 5. made by project, one of these other alternate pipes will 9
j 6: be used."
g R
i 7
g Could I see that a moment?
j 8
A Yes.
J 2
9 4
These deletions at the bottom half of the
?
10 page, have you addressed those and are they yours?
l y:
E h
II A
Yes, this particular group are mine.
l 3
l
'd 12 l MS. BLOOM:
These are deletions at the bottom l
=
g 13 of page five of Exhibit 6?
l m
5 14 MR. PATON:
Yes.
-=
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15 BY MR. PATON:
(Resuming) t
=
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16 q
Would you tell us why you deleted those words?
A i
17 A
Change from wrong to right.
l 5
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18 G
That isn't particularly helpful.
I assumed
[
i
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you were going to change it from wrong to right.
19 5
20 l 1
As it was written it was incorrect, that's all, 21 and I can't read'what some of those words were.
22 g
I want to know why you changed it.
23 A
Whoever wrote that section didn't.have a 24 sufficient understanding of the operation of the hammer l
l l
25 land made a couple of misstatements.
d' l
l I
i 1
ALDERSON REPORTING COMPANY. INC.
i 102 i
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4 Could I see that?
l 2
A Yes.
i 3
G What mistake did the person make?
4 A
It says the valve mechanism of air hammer g
5 will be so maintained that the position of stroke, length nM j
6 of stroke, and number of blows per minute for which the R=
7' hammer is designed will be attained.
~
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That statement is incorrect because it is not
-s 9
the valve mechanism that you maintain to cause this to
?
f 10 be true.
E 5
11 4
Okay, thank you.
j m
12 i
i on page six, is this your change here from j
^
n l
13 ' 37,500 foot pounds to 37,375 pounds?
l l'
s" I4 A
Yes.
+=
1 j
15 4
Why did you change that?
g 16,
A Secause there is a commercially available l
r, n
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I7 hammer of 37,375 which would be-ruled off course a
1
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5 18 to read 37,500 with that degree of rigidity.
j i one were
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19 g
4 Resulting, I assume, in unneeded expense if n
20 you tried to purchase one at 37,500, is that correct?
2I A
That's correct.
0 On page six in paragraph 7.1.5 you changed l
22 23 I will ask you if you changed driving caps to 24
?
drive n
'S I t
A Heads, I believe.
i 1
1 ALDERSON REPORTING COMPANY. INC.
4 i
103 1
G Drive heads.
If that's your comment, can you 2
tell me why you made that change?
l 3
A For clarity.
Talking about cap blocks in 4
here and driving caps, and I see all sorts of confusion i
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5 that can arise because driving caps is not the term s
j 6
that's ordinarily applied to what is usually called a 7
helmut or a drive head.
Xj 8'
G Do you know who prepared these suecs?
Were C
O 9, these prepared by Bechtel?
?
?,
10 '
A Yes.
?
-]
11 G
Do you know who within Bechtel?
3 d
I2 i A
No.
~
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Do you krow whether -- is it Mr. Chen or Dr. Chen?-
a m
5 14 1
I don't know.
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15 G
Do you know whether he reviewed them?
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16 A
I am certain that he has, but s
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17 MS. BLOOM:
Can we go off the record?
l u
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5 18 (Discussion off the record)
E 19 g
MS. BLOOM:
On the record.
5 20 '
BY MR. PATON:
(Resuming) 21 G
Is there any date for finalizing these j
22 specifications that you are aware of?
1 23 A
No, I am not aware of what anybody's schedule I
~
24 is now.
l
~i f
25 ;
4 In the paragraph on page six numbered 7.2.1 I
1 ALDERSON REPORTING COMPANY. INC.
104 l
I I see a comment -- I see two comments.
One is " reword,"
2 and one is "cannot do."
3 Would you address the cannot do first and tell I
4 I me what it is that you cannot do?
4 5
A "The pile shall be supported in rigid leads I
- l a
j 6
that extend to within two feet of the elevation the l
R 1
=
7 pile enters the ground."
i 8
n That cannot be done with the system that we c
9
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are going to use to install these piles, which involves 0
10 fj having the hammer and the leads above the roof of the
=
II service water cump structure.
3 12 i
G Okay.
Would you tell me.why you want them to f
13 reword that first sentence?
What is~it -- is it misleading, 3
14 3
or wrong, or what?
u 15 g
A
.Well, it's a ridiculous requirement limiting l
16 it to a handling str of 21,000 psi.
a 17 I
d 4
Tell me wh st is ridiculous.
Tell me a 2
=
i 18 '
- little more.
I understand your-conclusion, but what's i
8 3
ridiculous about it?
l l
20 A
If you pick up the pile and you haven't put 21 i
a sweep in it, then you have picked it up satisfactorily.
l 2
C On page seven you have deleted paragraph i
23 7.3.6 and you have the word "why."
What exception did 24 t
you take to that paragraph?
I f
25 '
A Somebody's probably been reading the literature i
~
1 ALDERSON REPORTING COMPANY. lNC.
i 1
105 i
i 1
l I, and applying the latest fads and fantasies and wanted to use bitumen as a means of reducing any skin friction, 2
4 3 jparticular negative skin friction, that conceivably could 4
develop.
I suggested that we not use that approach.
g G
Is bitumen coating not effective?
{
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A rei s effee 17e, i
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G For this purpose?
A j
8 A
Yes.
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G It is effective?
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t y
10 A
Yes.
I z
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G Why are you deleting it then?
I 3
y 12,
A Because we have decided to eat the load rather
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There is a great deal of care
=
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I4 that goes into that.
It would be a Q operation, and I t
j 15 dare say that it looks now that Midland _may not get j
i j
16 built if you got into that operation for a lousy sixteen j
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"2 1'7
-m.iles.
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18 0
br. Davisson, I see some notes that follow.
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19 Page seven -- under your name or letterhead dated 12/15 --
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20 ' are these notes that you inserted in these specs after 2I you received them?
]
22 A
No, that was a loose sheet that had my notes 23 j en it that I made during the meeting.
i 1
24 j q
These were included in the tech specs when i
25 i you received them?
i i
ALDERSON REPORTING COMPANY. INC.
s I
106 1
A No, I made these notes during the meeting where 2
the specifications were discussed, and it happened to be 1
3I loose, lying with this spec, and whoever copied left i:
4 in the same position and just stapled L: in.
t s
5 4
I see.
Do the notes refer to the tech specs?
?.
I j
6 A
Probably.
R 7
O The subject of these notes is the tech specs?
nj 8
A (Pause) a 9
Yes. in part they do.
5 10 okay.
3 11,
A Particularly the part where I recommended
-j j
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j 12 against the bitumen.
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Okay.
In the middle of page eight, Dr.
=
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14 Davisson, on the left side of page eight, did you write
~c 15 the words over here that seem to begin with the word EW 3
j 16
" check"?
What are those words on the left side?
Can s
17 vou read that?
I a
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18 1
Somebody had a recollection that a represen-t 19 tation had been made to NRC about redriving tha piles.
M 20 ' I think the suggestion was that we doublecheck that this i
21 is consistent.
j l
22l 4
Okay.
Have you made-any other comments with l
i 23 l respect to these particular specifications other than
~
24 what are listed in this Deposition Exhibi 6?
25 '
A No, that's the last thing that'was done.
i i
ALCERSON REPORTING COMPANY. INC.
s
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1 I
(
1 G
On page thirteen in paragraph 11.2.2, the.
t i
2 first sentence reads:
"Where anchor piles are used the 1
3; arrangement shall consist of at least fo ir piles with a I
4 minimum of two piles on each side capable of resisting i
5 a load a minimum of 300%," which appears to be changed l
[-
l H
j 6
to 150%, but I'm not sure, "of the design capacity of l
6 7lthe test pile."
i l
4
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8 Did you make a change there from 300%?
4 0
i 9
A Yes.
Z.
4 I
10 G
Can you tell me why?
l ez
=
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Well,-if you are going to have two piles on each 3
5 12 ) side, you take 150% and the total of those make 3001.
t 13 It's just a matter of how you word the sentence.
l
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Okay.
You look at that more as a grammatical
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That's for sure.
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On page fifteen on the righthand side t
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Yes.
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What is unclear?
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Well, it icoks like they were going to make 23 pull out tes on a pile that had been driven for a
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ALDERSON REPORTING COMPANY. INC.
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Through the fill and to the till.
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Okay.
I thought you said through the till.
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" Add NSF test" something, increments.
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All right, I see.
To the left of paragraph 8
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Okay.
The subject that you are talking about
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Transferring the load'-- jacking the load 21 into the structure.
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I see.
Who was going to undertake that i
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li ALDERSON REPORTING COMPANY. INC.
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with what had been proposed within these tech specs?
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This one left it to the subcontractor to work 3 j out the transfer system, and while this might be satis-l 1
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You have expressed on a couple of occasions 23 l some unhappiness, at least I construed it, with NRC 24 requirements.
Is that because you think -- well, because i
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1 Yes.
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MS. BLOOM:
I don't know if we want that in.
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MR. PATON:
Oh, I think it's right on the money.
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Yes, but 2,
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And this would be --
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This would be clearly admissible
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If it pertains to the service j
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Is that.what you are indicating?
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1 I would hope that is the case, yes.
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Who is that lower-level employee?
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Well, we haven't established -ha 4
it relates to the service water structure, and we have s
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(Resuming)
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What NRC employee did you have in mind?
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MS. BLOOM:
Again, let's establish that it O
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L-3 II BY MR. PATON:
(Resuming) 4 3
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Okay.
What employee is that?
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Again, we haven't talked about the I
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service water structure, and that's what we are 2M 20 '
MR. PATON:
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That's what we are talking about nowd 2I j
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MR. PATON:
I don't care.
Dr. Davisson has I
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That's clearly admissible, even 23 ; at a hearing, and even more admissible at a deposition.
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1 MS. BLOOM:
Well, no, I doubt it.
If Dr.
2 Davisson doesn't like the guy because he ran over his let's get a foundation.
3 foot or something, 4
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No, I don't think he clearly --
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(Resuming)
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Dr. Davisson, what NRC employee were you j
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Again, put down a foundation.
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Now wait a minute.
Now listen.
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21 what area we're talking about.
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Okay.
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What is the area of involvement of this NRC i
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say imposed some requirements that might not have been i
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I have not been informed in writing as to
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what the outcome of all this is.
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representation.
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Okay.
You read the depositions -- what 19 j
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I think he said what ocinions and i
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I think he said the t
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24 MR. PATON:
The borings is hardly --
25 '
MS. BLOOM:
Additional borings.
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ALDERSON REPORTING COMPANY. INC.
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an apt description of what he 1
MR. PATON:
1 2
disagrees with.
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Ms. 3;COM:
Additional borings.
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What about the borings don't you like?
What S
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Did you ever hear that this request for z
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Yes.
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Wait a second.
I don't think --
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2 MR. PATON:
Well, if he can't, he can't.
3 MS. BLOOM:
You asked him at a professional 4
level why he disagreed with Mr. Kane's request for f
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should go into it any further.
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He answered that question.
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I heard that they wanted some 4
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(Resuming) 2 g
4 Do you disagree with their position?
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Yes.
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Yes.
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moment.
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In your opinion are the NRC requirements in do they exceed those for the piling at Bailly?
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5 MS. BLOOM:
One moment, what NRC requirements?
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6 MR. PATON:
If he doesn't know, he R
7, MS. 3 LOOM:
No, there's a lot of requirements.
8 There is the regulations called requirements, there's e
9 MR. PATON:
That's fine.
I ask the questions I
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Lay a foundation --
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Lay a foundation.
It's not a t
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By this time
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I'm objecting to form.
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requirements are you talking about?
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MR. ?ATON:
Okay.
Could you answer --
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What requirements are you talking
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i 24 MR. PATON:
Fine, I understand your obj ection.
i BY MR. ?ATON:
(Resuming)
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ALDERSON REPORTING COMPANY. INC.
/
1 117 4
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Will you answer the question, please?
2 A
Let's go back and find out what that question i
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Okay.
In your opinion do the NRC requirements I
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6-differ from the NRC requirements for piling at Bailly?
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7 MS. BLOOM:
I don't think there's oeen any M
8 comparison between Bailly and the service water structure 1
9 at all.
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He has already testified he acts
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3 5.
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Excuse me, but there is'no i
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If he says there is no comparison, l
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I as asking and he is answering.
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16 THE WITNESS:
First of all, they are different n
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consistent.
I have not heard that NRC has said what-the l9 l
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requirements would be.
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(Resuming) 22 j G
You mean you don't know what the NRC re-i t
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You do not know?
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A I don't know that they have set any requirements.j 2
MS. 3 LOOM:
I think he testified to that 3
3 ' earlier when you started out on that this morning.
4' THE WITNESS:
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(Resuming)
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A general question with respect to the c
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tech specs that we have been talking about.
Is there any If 5
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Are they nearly final, are 3
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Have you performed any pile: load test to i
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37 determine the lateral load carrying capacity of the piles x
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18 at the service water structure?
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A No, not that.I can recall.
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Has Bechtel made any settlement estimates i'
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Yes, certainly they have.
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Do you know what they are?
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ALDERSON REPCRTING COMPANY. INC.
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I don't recall.
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Is the estimate of settlement within the l
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A Yes.
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Do you have any recollection of when you H
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A Ch, I think it was considered in the fall of 1980.
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just a minute.
Let me take a look at it.
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(Pause)
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specifications for Midland?
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I reviewed a concrete specification that came s
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I4, in response to my request for that, and I believe it was 15 j
a general concrete spec.
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I show you a one page letter from M.
T.
1 I7 Davisson to Dr.
S.
S.
Afifi which I am marking Deposition l
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18 Exhibit 7, Davisson, 1/14/81.
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l9 (The document referred to was s
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marked Davisson Deposition i
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Exhibit No. 7 for identifi-t 22 cation.)
I 23 MS. 3 LOOM:
What's the date?
24 MR. PATON:
It's dated April 15, 1980.
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25 37 MR. PATON:
(Resuming) f
.i ALDERSCN REPORTING COMPANY. INC.
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G I direct your attention to the last two 2
sentences of that letter which I would like to read for 3
inhe record:
l 4 I "Please note that we cannot reasonably meet 5
g section 11.5 (rimit of six-foot drop) and section 11.6 n
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(vibration).
This should be clarified."
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Yes.
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what does that mean?
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be to drop it from the top, whatever length it might be.
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You would drop it more than six I
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Changed?
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Yes.
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Okay.
Dr. Davisson, are you aware _that here i
25 are current discussions going on between the Staff and 5
- l ALDERSON REPORTING COMPANY. INC.
l 121 l
I Consumers Power concerning the seismic requirements 2
for the Midland site?
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I have heard that that is the case.
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Off the record.
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8 (Discussion off the record) l i
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MS. 3LOCM:
Let's take a break now.
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(Short recess taken) i z
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(Resuming)
,i 3
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- With respect to the considerations of alter-12 E
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alternatives considered to provide a stable, solid i
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16 structure down to the glacial till rathe'r than the piles?
1 l
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Yes.
6
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I have no knowledge.
It was one of the 19 a
20 obvious options that war. thrown on the table back then, 2I and I cr.n guess why it wasn't.
I 22 It would have involved a dewatering operation, 23 and that could be rather difficult.
I 24) 4 Do you know whether an analysis was done,to 25 l assure that the long longtitudinal bolts which will be i
ALDERSON REPORTING COMPANY,INC.
123 I
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Okay, I'm ready to answer.
1 3j G
Go ahead.
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The pile requirements as of the middle of i
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December appear to be for a compression ultimate test g
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8 The net usable load would then become 270 tons.
._a z_.
It appears that this is controlled by the dynamic in-9 l
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12, of safety consistent with Bailly, leads to a 270 ton 3
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16 inch,and various wall thicknesses.
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18 drilled to the till -- ac.c.roximately elevation 600.
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s The piles would be fabricated over the length so tha l
19 l
n 20 they will stick up in the air far enough to come up f
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- leads in the hammer used for driving the piles can l
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The piles are then driven down through l
25 l pre-drilled section~to bearing in the till at whatever i
ALDERSON REPORTING COMPANY. INC.
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elevation they find bearing in the till.
The piles i
2 would then be cut to an elevation suitable for working 3 ! below the corbel.
4 The corbel would have to be constructed --
5}inthemeantime, of course, the piles would be con-g i
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creted.
Then the piles would be preloaded, pretested R
7 before fastening into the structure.
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There is an open question at the moment for I
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10 we can pretest concurrently for at least two piles at
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14 at one time and apply loads greater than the working u_
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n 20 My notes are not complete as to what we had 21 lined out on the blackboard-at that time, but'in concept, f
22 j with some possible slight-modification of details, we l
23 ' ar e talking in terms of loading the-piles to 210 tons
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24 and cycling tne load several times.
i 25 !
Then we will hold the load, perhaps at 210 i
li ALDERSON REPORTING COMPANY. INC.
242 i
I tons constant, and observe pile settlement versus time 2 j until we get to a relationship of settlement versus time 3 }lcha:reasonable engineering can extrapolate in the 4
- ifuture, 5
g Then the pile will be locked off at a pre-n 3
6 determined load into the structure.
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into the structure.
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piles before the final lock-off takes place.
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Then the piles will be locked into the i
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structure, and whatever structural details Bechtel might
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then be constructed.
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I think that reasonably covers it.
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Would you explain the process of jacking and a
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locking in?
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The corbel will be in place -- really it c
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I9 ought to be called the pile cap.
I'm not sure corbel n
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is the correct term for what is being designed and con-
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21 structed here, and a set of details have to be designed 1
22 l to allow the insertion of a jack and jacking the load 23 ) against the pile ~ cap in such a manner that we can, by 24 ;
! combination or snas plates,or spacers and shims, weld 2
25 ;
i it in place before the load is released from the jacks..
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ALDERSON REPORTING COMPANY. INC.
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1 By effecting the stress transfer -- or pardon 2
me, load transfer -- part of the control technique 3
for doing this is that one can observe the differential i
i 4 4' displacement between the pile and the gap or absolute 5
a as the case may be, and observe at what point a given n
3 6
load is attained, and one can shim until upon release i
n E
7 of the jacks this differential is attained.
Once n
i 8
F' that's attained, it can be welder. in position and locked J
off final.
E 10 E
S What is your responsibility with respect to 1
11 g
the process of jacking and locking in?
'i 12 3
1 I expect I probably will have a representative t
13 I
i there who will be controlling that.
t E
14 d
G Okay.
Do you know whether pile end bearing capa-*1 I
15 city is planned to be determined by soil tests in the 16 d
drained condition?
6 1:7 0
1 No, it's going td be determined by load test.
E 18 MR. PATON:
Off the record.
+"
19 j
(Discussion off the record) t 20 BY MR. PATON:
(Resuming) 21 Dr. Davisson, I hand you a piece of paper --
22 ) well, first of all let me mark this Deposition Exhibit 3, i
23 *i Davisson, 1/14/31.
94 1 i
(The document referred to was s
25 marked Davisson' Deposition 1
ALDERSON REPORTING CCMPANY. INC.
l
127 i
i I
Exhibit No. 3 for identifi-2 cation.)
3 gy 33, rATON:
(Resuming) 4 g
I will ask you if you would draw a sketch 4
5 showing what you intend to do for jacking, shimming, d
n j
6 and locking in.
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?
A Okay.
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I'm showing.this schematically, because this z.
10 3
cannot be finalized until our contractor is selected.
3 II g
Okay, fine.
3 12 i
A I am giving you the cartoon, which merely I
13 5
shows the cile cap bolted to the wall of the structure a
l Wz 14 ' or oile --
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g would you mind *- you pointed to something i
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t 1'7 i
H in?
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A All right, I will call that the cap.
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"m 19 (Indicating on drawing) n 20 '
S Okay.
21 A
Shows the pile, the pile cap, and the building.
.i 22]
,3c,,c3,m,31c,117 e3, 37
,u11c 3,cx 21 3 p, cf 3
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23 the spacers that will be an integral part of the i
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ALDERSON REPORTING COMPANY. INC.
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I show a mark over here that indicates a level l
2jthat could be used in conjunction with indicator rods f
1 3 l ec observe motion of the building as well as of the 4 ' pile when the jacking takes place, c
5 These details will need to be designed t
6 finally when a contractor is selected for performance i
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7 of this work.
l
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8 MS. 3LOCM:
Do you have any more questions e$
~
9 Z.
on this?
10 MR. ?ATCN:
No.
z 3
II MS. BLOCM:
I want to get it copied.
i 3
12 E
SY MR. PATON:
-( Re s uming)
=
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l I4 5
15 g
30, t
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Sefore the surcharge placement, were you a
h II aware that the diesel generator building had shown I
- j 18 several cracks?
(
"a 19 1
I can't say that I was.
It was not my i
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20 project, and what I heard about it was perhaps less 21 conversation than it was by osmosis.
22l 4
Do you know whether any consideration was I
- 3 ' given to the possibility that the building cracks might
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i 25 ;
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ALDERSON REPORTING CCMPANY. INC.
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129 i
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G Did you have any input into the seismic l
2 analysis of the diesel generator building' I
3
.t 30.
4I C
Were you involved in the decision to remove s
5'the surcharge load from the diesel generator building?
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go, j
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To your knowledge, who -- do you know who 7
G 8
recommended the timing of the surcharge removal?
d 9
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- couldn't say specifically aho did, no.
z f
oy 10 4
Do you have any professional judgment con-E i
II cerning the time of removal of the surcharge?
l 3
Y I2 A
Yes.
=
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I was about to object to that
=
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We haven't talked about it at all, and :
Ej 15 haven't even talked about it with him, but we haven't
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s
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17 On the other hand, if you want to answer, you 3=
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18 can answer.
19 2
THE WITNESS:
Yes, I have a judgment.
R 20 SY MR. PATON:
(Resuming)
J J
Can you tell us what that judgment is?
I 2I i
22 l
.t The time that the pr'eload was left on is l
?
i 23, adequate to supply the data that was needed for future l
24 ' pro j ection o f the settlement of that structure.
25 4
!s that judgmen based on vour own orofessional ALDERSON REPORTING COMPANY. INC.
i
130 I
s I
qualifications, or are you relying on other person's 2
professional judgment.
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A Based on my own.
I have performed many pre-4 !1oading projects in the course of my engineering practice.
e 5
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pietometers in reaching that judgment?
t
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Yes.
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Do you know the ground water level during --
L 2.
in the vicinity of the diesel generator building during 9
10 the entire time the surcharge preload was on?
l
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There was a change in it as I recall.
t 3
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My question is do you know what the ground
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I don't recall.
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Isn't that a factor that confuses the analysis l
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17 consolidation?
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A I didn't see any-confusion.
a Well then, do you know -- do you know what the 19 I
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20 ground water table was?
j 21 1
I don't recall what it was.
22j q
Did you know what it was?
I 23 i A
.I looked at the data at one time, yes.
(.
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And you didn't see any confusion?
f
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25 x
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1 ALDERSON REPORTING COMPANY. INC.
1 i
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131 I
g So, it was clear to you, even though you may 2
not recall right now, it was clear to you at that time
,i 3 jprecisely what the ground water level was during the s
4 Ientire time of the surcharge at the diesel generator 2
5 building?
A 2
6 A
I don't recall having any question on it.
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Ckay.
I sure wish we knew.
There was a i
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8 time right around surcharge when the level of the pond u
9 or possible -- during z.
was changed, is that correct 10 the surcharge?
l z:
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I don't recall the detail of that at the a
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I know that there was a water level change of
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In your analysis -- well, you agree that j
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16 consolidation?
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-Yes.
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What is your basis for that?
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The shape of the curve, observations.
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4 The shape of the curve -- is this plotting 21 pie ometer elevations or what?
I 22 A
Settlement versus time.
[
23 g
S.ettlement versus log time?
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t.
24 A
- Yes, t
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And your pie:cmeter behavior to your knowledge 25 t
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ALDERSON REPORTING COMPANY, INC.
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i 132
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i was entirely consistent with your conclusion that it was I
2 in secondary consolidation?
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A Yes, the flips that occurred in the pie:ometers 4 jare in agreement with the change in the loading that c
5 took ulace.
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Is it true that the removal of the surcharge R
7 fit in very precisely with the schedule of work on the 8
diesel generator building?
l s
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I am not aware of what the schedule of work was.
z 10 C
With respect to the diesel generator building, z
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that correct?
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It's my understanding.
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And the pedestals are not connected with the l
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15 wall footings for the diesel generator building, is that
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m N
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I do not know.
a=
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Was there differential settlement at the
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diesel generator building?
n
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Yes.
^
21 G
Did you review any data relating to the l
l 22 surcharge program before the decision was made to remove 23 li the surcharge?
24f.
at that particular moment, I did 1
I did not 25lnot in any detail.
That was not my charge.
3 l
I, 1
ALDERSON REPORTING COMPANY. INC.
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4 Okay.
2 A
I saw it as a matter of interest for my f
3 ! colleagues.
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Dr. Davisson, I want to show you a page three e
5 of a note to the file dated August 6,
-- page one is 9
j 6
dated August 6, pages two and three are dated August 7.
A l
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I am not sure why that is, but
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8 MS. 3 LOOM:
Is this going to be an exhibit?
l C
.--- 2----- ~... __.._ __ _ M. R._.P AT O N :
This is part of Deposition
' ' ~ ~
2 10 Exhibit 5.
I
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5 II MS. BLOOM:
Yes," a twenty-page document.
t 12 5
MR. PATON:
Right, and this is in the middle r
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"Dr.
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5 I4 Davisson noted that we thould look hard at connections 9
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15 g
of utilities to the diesel generator in the. building, i
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N I7 foot movement in any direction."
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18 SY MR. PATON:
(Resuming) t s
S Let me show you that note and ask you do you l
19 5
f 20 l
recall making that statement?
A (Pause) i.
2I With respect to this specific sentence, I l
22 23 j do n ' t recall that one.
I have examined the subject I
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1 ALCERSON REPORTING COMPANY. INC.
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G You say generally you do not recall that t
2 discuss on?
A I do now.
Now that I have seen the notes there 3!
v general recollection of the discussion.
4 !! have a g
?
Okay.
Why do you think allowance for a one 5
n 4
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foot movement was appropriate?
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8' fically, but I do recall what the general topic of J
9 conversation was at the moment.
z.
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10 II here.
At these meetings each consultant had the area I
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for which he was specifically responsible.
However, if 12
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14 i
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16 There have been remarks ranging from cratuitous I
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17 extremely useful that are thrown on the table by the to w
18 consultants on_other parts of the project for which they
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20 So, there has been some interchange of this i
2I all through it.
However, where you've had more type 1 than one consultant at any given time, and this particular 22 23 discussion was one when -- I think it took place at a i
2#
time when they thought there might be some pockets-1,i of loose sand, and I was raising the question as to 25 i
I ALDERSON REPCRTING COMPANY. INC.
135 1
1 1 ;whether operation of the diesel engines themselves induced 2
sufficient vibrations to shake some of these down a I
3 llittle bit, and if se, it would be a good idea to shake 1
4 jthem down before any final connections are made.
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5 7
Do you know the status of that recommendation 5
j 6l right now?
1 E
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No, I do not.
I' u
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8 4
okay.
9 A
I have a recollection that as information i
h 10 l became better -- as they got more information on the
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13 investigation was made of the machines themselves.
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5 I4 As I recall they are V-16's or V-12's, and a j
l 15 pretty well balanced machine.
i 16 g
C Okay.
Are you aware that there were two A
d 17 Category I borrated water storage tanks on fill?
l u
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I have heard the subject mentioned, but I
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g have had nothing to do with it.
19 i
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Okay.
You could not, then, describe the l
21 foundation configuration of these tanks?
22 }
A I cannot.
23 4
Do you know whether there is a consultant to i
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24 3echtel with respect to the borrated water storage tank?
1 I
25 l A
I don't know.
6 i
ALDERSON REPORTING COMPANY. INC.
s
I 136 I
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1 4
Do you know whether there is a soil settlement l
i 2
croblem with rescoct to the borrated storage tanks?
I I
i 3i A
don't know that either.
f 4 i G
Okay.
I want to show you the response :o n
I e
5 question forty-one.
l
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MS. BLOOM:
Can we make it an exhibit?
R 7
MR. PATON:
No, no way.
Off the record.
~
8 (Discussion off the record)
L 9
MR. PATON:
On the record.
i l
=
10 3Y MR. PATON:
(Resuming)
E Il 4
I want to show you a response to question i
3 f
12 forty-one and specifically direct your attention -- it l
s 13 starts I think back here on page 41-1, Service Water
=
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14 Foundation.
--sj 15 Let me ask you this:
right now do you have
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it says " Revision j
16 any recollection as having read this W
d l'7 10, November,
'80."
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18 A
Probably had some input into it, but again, t
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that filtered through geotech and worked its way to l
5 20 that document.
t 21 G
Okay.
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- am certain I had some input.
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G Now, we see a statement on sheet four of i
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24 ] four attached to the answer to question 41 that talks about j 25 ; soil drained paramaters.
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1 1
ALDERSON REPORTING COMPANY. INC.
I 137 6
1 A
Yes.
2 g
I want to ask you if you will take a look l
3, at that and agree with my conclusion that that indicates 1
1 4
that page four indicates that pile and bearing capacity i
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5 is planned to be determined by soil test in the drained i
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condition?
R 7
A (Pause)
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2 9
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drain analysis of it.
10 g
You say they have made or they plan to make?
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It looks like an analysis on the assumption
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12 of drains -- soil drained paramaters.
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An analysis to be done?
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No, it's made right here.
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Oh, I see.
Okay.
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Yes, it's made right here.
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4 I see.
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It's probably playing _a game again.
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19 2
4 What is playing a game?
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A You have got to make a calculation, even l
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21 though you are going to determine it by a test.
i 22 You mean you think Bechtel is playing a game 23 because they are forced into it because the NRC is asking I
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24 l them to do that?
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A Well, let =e read the question and then I'll 1
i ALDERSON REPORTING COMPANY. INC.
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I 138 i
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1 answer that.
2 (Pause) i 3
That's essentially it ask a foolish question, 4
strike that as facetious.
and you get a foolish answer 5
g G
No, don't strike it.
Leave it on the record, n
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6 and if they want to strike it, they can ask the board R
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S 7
about it.
2 i
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In your opinion such analysis is not necessarv?
l J
9 7.
i It did not serve a useful c.urt.ose here.
t 10 5
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- Okay, II A
It served a political purpose, but not an en-3 12 '
i gineering-wise useful purpose.
g 13 G
Sy that you mean -- by political purpose I i
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14
?
gather you mean they are giving it to the NRC because I
15 h_
the NRC is asking for it?
I E
I0 A
That's right.
I m
l'7 is this the same i
d G
This gets back to the same
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18 subject as the horings that the NRC is currently asking for?
I b"
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A Yes, that's foolishness also.
I II I
f 20 G
Yes.
l 21 A
And to substantiate some strong statements, I l
4 22 j would like to add that it doesn't matter what shows in l
23 any of those calculations.
If the calculations say that 24 the pile will carry 300 tons before it fails, and it i
25
- 400, the calculations are wrong.
lactuallycarries 6
l 1
ALDERSON REPORTING COMPANY. INC.
i
139 1
If the calculations say 300 and it carries 2
200 tons, the calculations are wrong again.
But, if 3 j it only carries 200 we have some redesign to do, and it I
4 ! is the controlling item, and it's no the borings that's n
5 going to control here, nor is it the calculations of that 2
j 6
type because the pile capacity calculations -- if you i
R 7, want to do something about those theories, it's possible l
8 to get a fairly wide variety of answers out of a group
-J 9
z.
of competent engineers, and we are operating in full i
10 knowledge of the fact that this is the state of the E
11 art and that the best information will be obtained from a
f 12 tests.
E i
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Let me ask you to assume if you possibly can --
I 1
x 5
14 assume just for the sake of this question that such an i
t
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1 16 make that assumption, wouldn't you make the test with i
i I
17 the soil in the undrained' condition instead of the E
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y 18 drained condition?
- w 19,
A No, because the method of installation that I j
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20 have described for you clearly provides you with a drained 21 condition for each and every one of those piles.
22 i
G Did you attend the mes*.ing at the Federal i
23 } Highway Administration in June of 1990?
24l A
Yes.
l 25 l 3
Was there a discussion at that meeting of the J
l ALDERSON REPORTING COMP ANY, INC.
l
1 s
140 appropriateness of a soil strength test in the drained j
I 2
or undrained condition?
l 3'
1 I don't recall specifically, but at such a 4
=cnference there are undoubtedly people who discussed e
5 the subject, yes.
t 3
6 G
You have no recollection of chat?
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A No, I don't, not at all.
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G Okay.
u 9
1 I was more than an attendee, I was a participant E
10 j
en that particular thing, and we were offered a great deal of data with which --
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6 12 z
G I'm sorry, what?
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A We were offered a lot of information with 3
14 3
which to make a prediction, and I think everybody had hF 15 to judge for himself the quality of data and the
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a 17 3
discussion.
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How did you determine the sheer strength of 19 j
the soil do be used in designing the piles?
20 A
I didn't.
i-l G
Did you get that information from someone?
2I i
22
[
A If anybody had to have that for any purpose
\\
p 3echtel got it.
t 24 0
You didn't need that information?
25 A
No, I did not.
I'm sure I have had some l
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1 ALDERSON REPORTING COMPANY. INC.
I 141 l
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discussions with the 3echtel people over what they used.
l
. in their analysis.
I am very liberal about letting people f
2 i,
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3 'using whatever they want to use n it, especially when f
4 ij the job is going to wind up being controlled by the test.
5 r
G Nhat does this mean?
n I
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MS. 3 LOOM:
It means we are lecturing.
R R
7 3Y MR. PATON:
(Resuming)
-n 8
n 4
In the event of an earthcuake will the
-4 z-condition of the soil near the pile tip be undrained?
=
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A Yes -- pardon me, I take that back.
It would l
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be drained or at least on the reload portion.
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l 12
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It will either be drained or at least on a x=
14 w
reload.
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G 7Lat will cause it to be drained?
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A The method of installation of the miles and i
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3 the pretesting -- 210 tons in the longtime holds to be
[
I i
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placed on that.
I mean, for certain it will hcVe been i
~
n 39 i
oreconsolidated to that load that a n v. time it now i
20 t
exceeds 130 tons that we will see it at least on a I
reload or a recycle.
I In the installation of the piles how much "3 ;!
time w4
4*
-ake to transfer the load to the Oiles?
^
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4 1
It might take several months.
i 25 '
i 4
Uith respect to the electrical penetration 1
1 s
ALDERSON REPCRTING COMPANY. INC.
i i
142 i
f 1
area, do you agree that the caissons will be subject to f
2 lateral loads from earthquakes?
i 3
A Yes, there must be sone.
4 G
Do.you agree that the caissons will be subject 5
to lateral loads from earthquakes which will create g
n j
6 bending moment along the length of the caissons?
R b
7 MS. 3 LOOM:
That question --
M 8
THE WITNESS:
I have not i
d l
2 9
z, MS. 3LOCM:
3efore you go on, that questicn i
I y
10 sort of sounds like you are assuming there will be z=
j 11 earthquakes.
You are assuming again.
i 3
f 12 MR. PATON:
Well, he already answered the
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m
'A 5
l'4 MS. 3 LOOM:
The first part said if there is E
l 15 an earthquake.
Well, never mind, go on.
j i
j 16 THE WITNESS:
That was not part of anythina a
5 17 I have been asked to look at with respect to the electrical i a
3 1
3 18 penetration.
The same would apply to the prior question
~.
8 19 l
s that I answered, i
(
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20,
3Y MR. PATON:
(Resuming) l t
r 1
G What is your responsibility with respect to 21 22 the electrical penetration area?
l l
23 1
It's not well defined at the moment because i
24 they are adapting to the loss of Mr. Gould.
i 25 i G
Dr. Davisson, do you recall several hours ago l'
I i
l
. ALDERSON REPORTING COMPANY. INC.
1 I
I
143 1
l l
1 generally the question I asked you about the status of 2' :enstruction of the piles, and I read you a list outlining 3, alternatives -- quick design, pick an alternative, 4
refine the model, etc.
I was trying to find out where 5
g you were with the design of the piles at the service N
j 6
water structure, and I will repeat all those words if i'
R I
=
7 you -- if there is any need to.
l
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.A No.
-J 9
4 My question is can you tell me where you are z
10 z
i with respect to the remedy at the electrical penetration 5
Il ' area -- at what stage in the development of the remedy a
N I2 are you?
~
i 13 MS. BLOOM:
Do you understand that?
i i
3 14 THE WITNESS:
Vaguely.
p 15 0
t MS. SLOOM:
Do you want to break it down?
i
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I0 THE WITNESS:
I think I understand it well l
=
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17 1
enough to answer it.
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18 MS. BLOOM:
Okay, go ahead.
\\
h I9 MR. ?ATON:
If you don't understand it, I can n
20 break it down.
[
ej THE WITNESS:
No.
I guess we are waiting for j
I 9
t a
22 l a little more definition as to what we might be doing 23ll on that l
l project, and when I say.we, I guess I mean me, j
24j because Mueser-Rutledge is involved with that now, and --
25,
33, pg7ag:
.m sorry, I didn't hear that name.
1 i
ALDERSON REPORTING COMPANY. INC.
4 144 1
i i
1 THE WITNESS:
Mueser-Rutledge is involved l
l, 2
with that project now, and I don't have the feeling
}
3 myself at this moment that I know exactly how we are going 4
to work together on this.
1 2
5 3Y MR. PATON:
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4 Okay.
My question, though, relates to your f
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ment of the remedy for the electrical penetra: ion area.
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The specifications have been O
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So, those details should be well in hand.
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Even after you have a contractor, there is I
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No, I don't.
I would say that what I as to do I
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i ALDERSON REPORTING COMPANY. INC.
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145 t
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I isolation valve pit, would your statement be the same as i
2 for the electrical penetration area -- that there is some 3
indefiniteness as to the scepe of your responsibilities?
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Now, with respect to the feed
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A I can't recall at the moment.
That detail has i
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I would have to go back and study it, and
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Do you view the feed water isolation valve pit l
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In other words, you may be. involved with j
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A Yes.
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Right now you are not too sure about either one?
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A Not sure, right.
21 MR. PATON:
Let's take a ten minute recess and 22]I think we will be finished shortly.
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1 23 (Short recess taken) i "4 l 3Y MR. PATON:
(Resuming) i i
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Dr. Davisson, did you say that during the l-i:
i ALDERSON REPORTING COMPANY. INC.
146 I
1 earthquake, or an earthquake, the soil beneath the pile 2
tip would be reloaded?
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A Yes, by the dynamic increment.
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Would this reload be under drained or undrained g
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It's in between the two.
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Let me -- do you recall seeing Exhibit 2, 1
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1 Yes.
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step one.
Stee two is that the same solution would be 19 l
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It is up 21 to the project structural to evaluate that and see if, 22 } in fact, the solution I have recommended is one that 23 fits in with your overall analysis.
24 MR. PATON:
I have no further questionse Thank- ;
i 25lyou, Dr. Davisson.
ALDERSCN REPORTING COMPANY. INC.
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3 147 1
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1 MS. 3 LOOM:
I have no questions.
2 (Whereupon, at 4:15 p.m.,
the taking of the i
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4 4!
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6 Signature of the witness R
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8 SU'!SCRISED AND SWORN to before me this day of l
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1931.
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